4 Amendments of Alfred SANT related to 2016/0337(CNS)
Amendment 76 #
Proposal for a directive
Recital 1
Recital 1
(1) CTax systems across the Union should be encouraged to remain competitive when this contributes to making the economy more attractive for investment and thus allowing for the preservation of a favourable fiscal environment for companies. Concomitantly, companies which seek to do business across frontiers within the Union encounter serious obstacles and market distortions owing to the existence and interaction of 28 disparate corporate tax systems. Furthermore, tax planning structures have become ever-more sophisticated over time, as they develop across various jurisdictions and effectively take advantage of the technicalities of a tax system or of mismatches between two or more tax systems for the purpose of reducing the tax liability of companies. Although those situations highlight shortcomings that are completely different in nature, they both create obstacles which impede the proper functioning of the internal market. Action to rectify thoese problems should therefore address both these types of market deficiencies.
Amendment 95 #
Proposal for a directive
Recital 2 a (new)
Recital 2 a (new)
(2a) Moreover, diversity of tax regimes may attract foreign investors to invest their funds in peripheral countries, regions and islands. Thus, diversity of tax regimes allows these regions to draw cross border investments that would otherwise locate elsewhere. As such, diversity of tax regimes is accepted as reasonable, useful and sustainable for peripheral regions, in order to stimulate job creation and new economic activities.
Amendment 151 #
Proposal for a directive
Recital 8
Recital 8
(8) Taxable revenues should be reduced by business expenses and certain other items. Deductible business expenses should normally include all costs relating to sales and expenses linked to the production, maintenance and securing of income. To support innovation in the economy and modernise the internal market, deductions should be provided for research and development costs, including super-deductions, and those should be fully expensed in the year incurred (with the exception of immovable property). Small starting companies without associated enterprises which are particularly innovative (a category which will in particular cover start-ups) should also be supported through enhanced super- deductions for research and development costs. This condition should prevent large Multinational Enterprises (MNE) from setting up supposed start-up companies, which in fact belongs to a MNE, in order to make use of the enhanced super deduction. Such enhanced super deduction will increase the amount of losses, which may be carried forward to be set off against future profits. Therefore, it provides for a prospective application of the enhanced super deduction. In order to ensure legal certainty, there should also be a list of non- deductible expenses.
Amendment 242 #
Proposal for a directive
Article 5 – paragraph 1 – introductory part
Article 5 – paragraph 1 – introductory part
1. A taxpayer shall be considered to have a permanent establishment in a Member State other than the Member State in which it is resident for tax purposes when it develops a turnover in that other Member State and when it has a fixed place in that other Member State through which it carries on its business, wholly or partly, including in particular: