Part 1 - AL-Tax

Contents7.3 Between routine risk and high uncertainty 1567.3.1 Traditional terminology 1567.3.2 Distinction between risk and uncertainty 1567.3.3 Intermediary results 1587.4 Classification of companies 1597.4.1 Function and risk analysis in the broader sense 1607.4.2 Selection of the type of arm’s length analysis 1617.4.3 Functional type: Risk versus uncertainty 1617.4.4 Functional density: Comparability versus uniqueness 1637.5 Arm’s length analysis 1637.5.1 ‘Routine company’ and third-party comparison 1637.5.2 ‘Hybrids’, budget planning, and budget-actualassessment 1647.5.3 ‘Entrepreneur’ and allocation of residuals 1657.6 Conclusion 166Acknowledgments 167Notes 167References 1688 Corporate Tax Competition and Coordination in theEuropean Union: What Do We Know? Where Do We Stand? 171Gaëtan Nicodème8.1 Introduction 1738.2 The European Union as a global power 1738.3 The institutional design of and rationale for taxation 1748.4 The evolution of tax receipts in the European Union 1788.5 Corporate tax competition in the European Union: Theoryand empirical evidence 1798.5.1 Tax competition and the underprovision of public goods 1798.5.2 What do theories of tax competition tell us? 1818.5.3 How well does the European Union fit the theory? 1828.5.4 Do European Member States compete on tax rates? 1848.6 The corporate taxation debate in the European Union:The early proposals 1878.7 The corporate taxation debate in the European Union:The 2001 Communication 1888.7.1 Comprehensive and targeted solutions 1898.7.2 Cross-border loss relief in the European Union 190viii