International double taxation a serious problem within the EU

NEWS Published

COMMENT It´s crucial that the EU and the Member States keep up with the work on eliminating Double Taxation within the Union and worldwide, writes Hussein Abdali, taxexpert, Confederation of Swedish Enterprise.

The recent international debate on corporate taxation is very much focused on addressing aggressive tax planning and erosion of the corporate tax base. At the meeting of the Platform for Tax Good Governance that took place on October 16, 2013, several Member States of the EU claimed that international double taxation no longer is a problem within the Union. International double taxation is when a taxpayer is forced to pay tax on the same income in two or more jurisdictions.

The view of these Member States was challenged by business representatives. To prove the contrary, the Pan-European business federation BUSINESSEUROPE approached some of Europe’s largest MNE’s to answer a questionnaire on double taxation. An overview of the responses was provided in a report entitled Double Taxation Cases Outside the Transfer Pricing Area, December 2013 (enclosed).

This study confirms that double taxation remains a problem and an obstacle for cross border trade and investments. In particular, the problematic areas are limitation in interest deductibility, foreign tax credits, permanent establishment issues and diverging qualifications or interpretations. Germany and Italy have been identified as the Member States in which most double taxation cases have occurred.

In addition to the actual cases where double taxation have occurred, MNE’s express concern that double taxation is likely to increase due to a number of new tax proposals in some Member States. Such proposals have been presented in France and Belgium in respect of limitations in interest deductibility and in Germany, France, Spain and Portugal in respect of loss utilization. Furthermore, MNE’s complain that, where double taxation has been avoided, the issue has been very resource intensive and has required restructurings with significant increase in administrative costs. Several MNE’s also bring up that they expect that OECD’s Base Erosion and Profit Shifting project will result in many more cases of international double taxation.

The responses from the large MNE’s are certainly not representative for illustrating the occurrence of international double taxation in Europe. If very large MNE’s encounter the number of international double taxation cases indicated in the report, SME’s can be expected to encounter even more cases. The cost of “getting it right” is in many cases out of proportion to the disputed amount in each transaction. The net outcome may therefore be abstention from cross-border activities as the tax systems act as a deterrent to investment and cross-border activities.

It is therefore crucial that the EU and the Member States keep up with the work on eliminating Double Taxation within the Union and worldwide. Furthermore, amendments in national, EU and international tax legislation must always be designed in a clear way so that the risk of double taxation is kept at a minimum.

Hussein Abdali

Ladda ner


NEWS Published:

Wanted: political courage for a digital single market

OPINION Though the EU single market has long since celebrated its 20 birthday, having caused increasingly free movement of goods, services, people and capital across the member countries borders, the digital dimension of these markets has remained largely national. This must change, writes Sophia Bengtsson, EU single market expert.
NEWS Published:

The future of corporate tax a hot topic

TAXES A recent seminar brought together 175 leading international experts from academics, business, and government to discuss the best way to tax international companies. The gathering highlighted the extensive current debate on how and where companies with international operations should be taxed. Companies are criticised for utilising the taxation system for their own gain, while countries introduce new tax regulations designed to attract investment.
NEWS Published:

Commissioner Malmström visits global leader Firefly

FREE TRADE EU Commissioner for Trade, Cecilia Malmström, made a quick visit to Stockholm based Firefly. “The daily operations of small and medium sized companies (SMEs) are a recurring topic in the transatlantic free trade agreement negotiations,” Ms. Malmström said.
NEWS Published:

Continued strong consensus on TTIP

FREE TRADE Swedish trade unions and employer organisations agree a trade agreement between the EU and the US, the TTIP, is important to Swedish companies and jobs. However, several issues must still be resolved, as with disputed investor protection clause.
NEWS Published:

Free flow of data can power European growth

INTERNAL MARKET The digital revolution is no small thing, write six representatives for the Confederation of Swedish Enterpise.
NEWS Published:

More Women in Managerial Positions

NATIONAL ECONOMY A new report shows that the share of women in managerial positions at all levels has increased among members of the Confederation of Swedish Enterprise. Currently, over one in three managers are women.
NEWS Published:

Free Trade Agreement boost for camera business

FREE TRADE An agreement on free trade between the EU and the US would simplify daily operations for manufacturers FLIR from Täby, just north of Stockholm. 99% of their production goes to export. “It would be easier for us to buy components internally from the US and sell finished systems back”, says Rickard Lindvall, General Manager for FLIR Systems in Täby.
NEWS Published:

Corporate governance is simply not suitable for a one size-fits-all model

OPINION In Europe we have an understanding that diversity in corporate governance models is important for our companies. This understanding is challenged by the European Commission’s proposal to revise the Shareholder Rights Directive, writes Carola Lemne, Kristin Skogen Lund, Jyri Häkämies, Almar Guðmundsson and Karsten Dybvad, Chief Executives of the Nordic Confederations of Industry.
NEWS Published:

EU falling behind in digitalisation

DIGITALISATION The Confederation of Swedish Enterprise hosted a seminar with the Latvian Embassy on the ‘Digital Future of the EU — Engine of European Competitiveness’. This highlighted the challenges the EU faces in global competitiveness and digitalisation. “We are far from having a common digital market”, was the message of the participants.
NEWS Published:

"Corporate governance is simply not suitable for a one-size-fits-all model"

OPINION In Europe we have an understanding that diversity in corporate governance models is important for our companies. This understanding is challenged by the European Commission’s proposal to revise the Shareholder Rights Directive.
NEWS Published:

“Swedish Government proposes anti-job spring budget”

BUDGET BILL The Swedish governing coalition of Social Democrats and Greens, recently introduced their spring budget bill, but which includes a series of proposals harmful jobs, investment, and enterprise, noted Carola Lemne, General Director of the Confederation of Swedish Enterprise. “It’s a dangerous path to follow just when Sweden’s competitiveness need reinforcing,” she added.
NEWS Published:

Red tape blocks Swedish exports

FREE TRADE Winches made by Sepson in north-central Sweden are used world-wide, but bureaucratic barriers delayed it from opening business for in the USA. “A free trade agreement would help our expansion significantly,” says Mats Elfsberg, CEO at Sepson AB.
NEWS Published:

Good for Sweden, Good for the EU, and Good for South Korea

OPINION The EU’s free trade agreement with South Korea has been in place since July 1 2011. The latest European Commission progress report on its implementation highlights the benefits gained by both parties. Facts that for all those who reflexively oppose international trade agreements should give good reason to pause and reconsider.
NEWS Published:

Big Data – Europe’s big break?

EU Europe is at a crossroads. How can we make sure to reap all the benefits of the data revolution and use them to our advantage? What challenges in our society can be solved by facilitating data-driven innovation in the EU? How do we remain competitive in an increasingly digital network of global value chains? Those and other questions were on the table at a seminar organised in Brussels by the Swedish Society for Politics and Business, SPN.
NEWS Published:

Growth and Investments – Necessary Conditions for Sustainable Development

OPINION Economic growth is often depicted as an obstacle to rather than a necessary condition for creating environmentally sustainable development. But this view is increasingly being questioned, as research and empirical data now clearly point to a convincing conclusion — that economic growth and investment are essential to stemming environmental and climate challenges, writes Nicklas Skår, environmental rights specialist.
NEWS Published:

Unpromising Swedish-Norwegian Energy Collaboration

ENERGY The red-green coalition government in Sweden announced an agreement with Norway regarding an increased Swedish interest in the European Energy Certificate System, and a bill is expected in the late April. Maria Sunér Fleming, Energy Specialist at the Confederation of Swedish Enterprise is critical to the announcement. “Implementing a change that hems in the recently appointed parliamentary energy commission, restricting it in any way is unfortunate,” she says.
NEWS Published:

”Our members send concerned signals”

THE SAUDI AFFAIR Cancelled business meetings and broken contracts have followed in the wake of the diplomatic crisis between Sweden and Saudi Arabia. Confederation of Swedish Enterprise General Director, Carola Lemne, finds the situation worrying and hopes the government can straighten out all misunderstandings as soon as possible.
NEWS Published:

Cecilia Malmström sets the bar for the world’s largest free trade agreement

FREE TRADE Finalizing a free trade agreement between the EU and the US rests in many ways on Swedish shoulders. Cecilia Malmström, the Swedish EU Commissioner for Trade, has joined the negotiations at a crucial stage. She needs to ease public concerns, placate opposition, and act as a driving force when the parties sit down to discuss details of the agreement. The Confederation of Swedish Enterprise’s magazine had an exclusive interview with Cecilia Malmström.
NEWS Published:

BUSINESSEUROPE Day 2015 "Invest in Europe"

On March 26th, BUSINESSEUROPE Day was organized in Brussels. The theme of this year’s full day event was “Invest in Europe”, and a large number of participants showed up from the business side and media. Among the speakers were President of the European Commission (EC) Jean-Claude Juncker, President of the European Parliament (EP) Martin Schulz and many more.
NEWS Published:

Easier exports with free trade agreement

FREE TRADE Small family business Ahlberg Cameras from Sweden, is a world leading manufacturer of camera equipment for the nuclear power industry. 90% of their production goes to export – with 50% alone to the US. But costly trade tariffs on sales to the US throw a spanner in their works. “A free trade agreement would make things much easier for us,” says CEO Joakim Ahlberg.