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Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Sandra Müller-Thomczik

Sandra Müller-Thomczik

Fern Universität Hagen, Faculty of Business Administration and EconomicsHagen, Germany
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Müller-Thomczik, Sandra
 e 
Lukas Reiter

Lukas Reiter

Fern Universität Hagen, Faculty of Business Administration and EconomicsHagen, Germany
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Reiter, Lukas
  
30 nov 2022
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Pubblicato online: 30 nov 2022
Pagine: 269 - 290
DOI: https://doi.org/10.2478/ceej-2022-0016
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© 2022 Sandra Müller-Thomczik et al., published by Sciendo
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.

Figure 1

Relevant aspects of the German system regarding causation justiceSource: Authors’ own figure
Relevant aspects of the German system regarding causation justiceSource: Authors’ own figure

Figure 2

Appearance of the objective resistance to manipulation in the German systemSource: Authors’ own figure
Appearance of the objective resistance to manipulation in the German systemSource: Authors’ own figure

Figure 3

Similarities and differences regarding resistance to practicabilitySource: Authors’ own figure
Similarities and differences regarding resistance to practicabilitySource: Authors’ own figure

Figure 4

Comparison of the objectives of splitting according to German corporate taxes and the CCCTBSource: Authors’ own figure
Comparison of the objectives of splitting according to German corporate taxes and the CCCTBSource: Authors’ own figure

Comparison of the similarities and differences of the apportionment according to the CCCTB-Proposal and the Trade Tax Act

Splitting according to CCCTB-Proposal Splitting in accordance with Trade Tax Act
Number of factors 3 factors 1 factor
Composition of the labour factor / content of the wage bill - Wage bill and number of employees (half)- Concept of employee varies according to national definitions - Wage total only- Definition of employee pursuant to § 7, para. IV, SGB IV
- Inclusion of social security expenses
- Inclusion of services to external parties who perform similar activities to those performed directly by employees
- Inclusion of temporary workers
- Presumably inclusion of vocational training
- Presumably inclusion of tax-free remuneration
- Capping limit
Alternative apportionment standards Possible
Lingua:
Inglese
Frequenza di pubblicazione:
1 volte all'anno
Argomenti della rivista:
Economia e business, Economia politica, Teoria economica, sistemi e strutture, Microeconomia, Macroeconomia, Politica economica
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