Head Office Taxation Rules and Simplification of Compliance Costs of SMEs

Abstract

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 an assessment of the proposed Directive’s impact on the strengthening of the EU internal market.

Keywords: European Union; Direct Taxation; Head Office Tax System; Micro, Small and Medium Enterprises; Permanent Establishments

JEL Classification: K33, K34, F13, E62, D78, E62, F02, F23, F42, H20, H22, H23, H25, H26, H87, O19, O23, O24