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Informationen zum Autor Antony Ting is a senior lecturer at the University of Sydney Business School. He was previously a tax partner in a major international accountancy firm, advising multinational companies on corporate tax as well as international tax issues. Klappentext The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common. Antony Ting presents the first comprehensive comparative study of eight consolidation regimes in Australia, France, Italy, Japan, the Netherlands, New Zealand, Spain and the USA. In the study, he critically analyses and compares alternative policy options with respect to ten key structural elements. The study improves understanding of the design and implementation of consolidation regimes and sets the stage for the search for a model. It provides valuable information with respect to the best practices, as well as the pitfalls, in the design of a consolidation regime. The book is essential to countries contemplating the introduction of a new consolidation regime and offers important insights into the management of such a complex structure through careful policy-orientated choices. Zusammenfassung Antony Ting critically analyses and compares alternative policy options adopted in eight countries with respect to ten key structural elements of a consolidation regime. This is the first comprehensive comparative study across a broad geographical spectrum and provides valuable information to countries contemplating the introduction of a new consolidation regime. Inhaltsverzeichnis Part I. The Enterprise Doctrine - Theory and Practice: 1. The rise of corporate groups: a challenge to the tax law; 2. Application of the enterprise doctrine to group taxation: theory; 3. Application of the enterprise doctrine to group taxation: practice; Part II. Comparative Analysis of Key Structural Elements of Consolidation Regimes: 4. Policy objectives and structural elements of consolidation; 5. Definition of a group; 6. Treatment of losses; 7. Treatment of assets; 8. Treatment of intra-group shareholdings; 9. Interactions between consolidation and other parts of the income tax system; 10. A model consolidation regime?...
