Translation of "imposition de groupe " (French → English) :

group taxation

Working Party No. 6 on the Taxation of Multinational Enterprises [ Working Party on the Taxation of Multinational Enterprises ]

Working Party No. 1 on Double Taxation and Related Questions [ Working Party on Double Taxation and Related Questions ]

double tax treaty | double taxation agreement | double taxation convention | double taxation treaty | DTA [Abbr.] | DTC [Abbr.] | DTT [Abbr.]

method of taxing | taxation method

tax bracket

double taxation agreement [ DTA ]

Finally, the Commission's decision that Belgium's "excess profit" ruling system was contrary to EU state aid rules was also based on derogations from the "arm's length principle". Profit allocation methods, which do not reflect economic reality: The Commission decided in August 2016 that Apple received illegal tax benefits in Ireland because the tax rulings endorsed a method to internally allocate profits within two Irish Apple group companies, which did not have any factual or economic justification. Inconsistent application of national law, giving rise to a discretionary double non-taxation: Today's ...[+++]investigation into Luxembourg's tax treatment of GDF Suez looks into an alleged inconsistent application of national tax law endorsed in the tax rulings, leading to double non-taxation.

125. Calls on the Member States, in a spirit of good cooperation, to endorse the proposals included in the Commission’s action plan of 17 June 2015 for fair and efficient corporate taxation in the EU; believes that the Group’s legitimacy would benefit from increased transparency and accountability; advocates therefore that the Group’s governance and mandate be reshaped, including through the appointment of a permanent, politically accountable Chair, the improvement of its working methods, including a possible enforcement mechanism, the regular participation in the Group by finance ministers or senior officials, in order to raise its profile, and ...[+++] enhanced information exchange within the Group with a view to effectively addressing BEPS issues; calls also for the criteria set in the Code to be updated and broadened in order to cover new forms of harmful tax practices, including in third countries; calls on the Chair of the Group and on the Council to regularly report to and exchange with its competent committee on the activities of the Group, in particular with regard to the presentation of its biannual reports to ECOFIN;

123. Calls on the Member States, in a spirit of good cooperation, to endorse the proposals included in the Commission’s action plan of 17 June 2015 for fair and efficient corporate taxation in the EU; believes that the Group’s legitimacy would benefit from increased transparency and accountability; advocates therefore that the Group’s governance and mandate be reshaped, including through the appointment of a permanent, politically accountable Chair, the improvement of its working methods, including a possible enforcement mechanism, the regular participation in the Group by finance ministers or senior officials, in order to raise its profile, and ...[+++] enhanced information exchange within the Group with a view to effectively addressing BEPS issues; calls also for the criteria set in the Code to be updated and broadened in order to cover new forms of harmful tax practices, including in third countries; calls on the Chair of the Group and on the Council to regularly report to and exchange with its competent committee on the activities of the Group, in particular with regard to the presentation of its biannual reports to ECOFIN;

The benefits of Directive 2011/96/EU should not lead to situations of double non-taxation and, therefore, generate unintended tax benefits for groups of parent companies and subsidiaries of different Member States when compared to groups of companies of the same Member State.