Head Office Taxation Rules and Simplification of Compliance Costs of SMEs

Journal
International
International Transfer Pricing Journal 2024 (Volume 31), No. 1
This study performs a legal assessment of the proposed Directive on Head Office Taxation, and puts forward alternatives to overcome the identified concerns. It is structured around the building blocks of the proposal: (i) scope; (ii) access to the regime; (iii) substantive tax rules; and (iv) procedural tax rules. The study concludes with policy considerations on the proposed Directive’s impact on the strengthening of the European Union’s internal market.