欧洲的公司税制

欧盟委员会正在考虑一种适用于整个欧盟的公司税收共同模式。但这种模式肯定是行不通的。因此,它应该考虑一种业已存在的,更为简单和可行的方案。

对公司收入的征税目前欧盟各国都有不同规定。其基础都是将公司在各个国家所得收入进行分别核算(SA)。公司内部的跨国交易根据类似交易的市场价核算—即所谓的“常规交易原则” (ALP)。

这种会计体系颇为复杂,管理成本高昂,并可能造成双重征税—因为各成员国通常不允许对发生在国外的亏损和税收义务进行完全销账。由于各成员国对公司收入的定义不同,再加上ALP所提供的大量舞弊机会(因为市场参考价通常不存在),使得避税非常容易,更别说将利润转移到低税收国家。

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