Please note the delivery estimate is greater than 7 business days. Special financing available. Any international shipping and import charges are paid in part to Pitney Bowes Inc. Learn More - opens in a new window or tab International shipping and import charges paid to Pitney Bowes Inc. Learn More - opens in a new window or tab Any international shipping and import charges are paid in part to Pitney Bowes Inc. Learn More - opens in a new window or tab Any international shipping is paid in part to Pitney Bowes Inc.
Learn More - opens in a new window or tab. Report item - opens in a new window or tab.
Seller assumes all responsibility for this listing. Item specifics Condition: Brand New: A new, unread, unused book in perfect condition with no missing or damaged pages. See all condition definitions - opens in a new window or tab Read more about the condition. About this product. Shipping and handling.
- Mysticism: Holiness East and West.
- Shop with confidence!
This item will ship to Germany , but the seller has not specified shipping options. Contact the seller - opens in a new window or tab and request a shipping method to your location. Shipping cost cannot be calculated. Please enter a valid ZIP Code. Shipping to: Worldwide. No additional import charges at delivery! This item will be shipped through the Global Shipping Program and includes international tracking.
Learn more - opens in a new window or tab. There are 3 items available.
Studi Tributari Europei, 2009
Please enter a number less than or equal to 3. Select a valid country. Please enter 5 or 9 numbers for the ZIP Code. Delivery times may vary, especially during peak periods. Handling time. Will usually ship within 2 business days of receiving cleared payment - opens in a new window or tab. Taxes may be applicable at checkout. Along this interpretation line, it is not clear what will happen if what is moved abroad is the headquarters or real seat, but not the registered seat. Insofar as the real seat theory is applied, the consequence of such a transfer may be expected to be also the dissolution and liquidation of Spanish company, without continuity of the legal personality.
For an important scholarly sector  , there are well-grounded reasons to interpret that art.
Exit Taxes and the European Community Law in the light of Spanish Law
Bigger problems would arise in the cases of transfer abroad of the registered seat, when art. Nevertheless, referred jurisprudence interprets that the field of application of these precepts should be limited to those unusual or exceptional cases where the seat transfer abroad does not imply a change in the Law regulating the company change of registered seat takes place, but the company continues to be under Spanish law .
- Shop by category!
- Honey the Rock Hound : A Puppy Dies A Family Mourns.
- Easy Landscape (2013 Edition) (Easy Photography).
According to art. In these cases, art. A combined reading of art. Nevertheless, a mere reading of these two measures may lead to incorrect conclusions, as these should be connected to what we have analysed above. At the same time, it is necessary to clarify when an entity can be considered as residing in Spain in terms of its personal liability to corporate tax contribution basically, all legal persons, except for common law companies with legal personality, and other entities that, although without legal personality, have a corporate tax liability, like, for instance, mutual funds or pension funds.
An issue made reference to by art. To these effects, it will be supposed that a entity has its actual centre of administration in Spanish territory when having there the control and management of the whole of its activities. A combined interpretation of art.
Not all changes in the corporate life have as consequence the tax liability and the application of art. The application of art. If the most traditional opinion among Trade Law scholars is followed, in the sense that such an option has as consequence the dissolution and liquidation of the company, art. However, if the approach we consider more correct were to be adopted, namely that the transfer of registered seat does not necessarily determine the dissolution and liquidation of the company and that it is perfectly possible in spite of the fact that no international agreement exists on this sense, art.
In this case, the rule of art. In such a case, it is also necessary to keep in mind the rules of art.
It is true that linking the interpretation of the above to art. It could be thought that art.
- Book of Wealth God Wants You to Be Wealthy and Prosperous.
- shiranaitoabunaihudousantoushinihisomuwana (Japanese Edition)?
- Del postmoderno: Critica e cultura in America allalba del Duemila (Studi Bompiani) (Italian Edition)?
- Forest Analytics with R (Use R!)!
However, probably art. Consequently, in our opinion, art. As we already commented above in the part dedicated to natural people, art. It is necessary to imagine a third hypothesis raising problems from the perspective of Community Law, regarding companies constituted abroad or in a more general way, entities but having in Spanish territory their actual centre of administration  or even when the transfer of the actual centre of administration is carried out together with the change of registered seat to Spanish territory .
Dual Resident Corporations Following ECJ's Centros Decision - - Germany
Also in this case art. Nevertheless, it is necessary to keep in mind that the differences in accounting for good can have their origin in the application of different accounting rules e. Regarding individuals, Communication of the Commission, section 2. After ECJS Kerckhaert  , in our opinion, the elimination of the double taxation must be guaranteed through coordination, without having to state that it intrinsically constitutes a limitation of the freedom of establishment.
In short, they are two situations in which an infringement of the Community freedom of establishment can take place:. It must be observed that in these cases Spanish Law will tax both capital gains generated before to the transfer of the actual centre of administration to Spain and the capital gains related to the time of residence in Spanish territory, with the result of making possible a double taxation as a consequence of the overlapping of Spanish taxation and the taxation of the State where the company is incorporated, when the actual centre of administration is transferred to Spain.
However, such a double taxation can be probably solved through Community legislative process or, if Spanish legislator wants it, through a change of TRLIS regarding these cases. Likewise, we should consider that ECJ, in its sentence N  , articulated a Community rule referred to the treatment of capital loss or loss of value possibly incurred by the company between the time of transfer of residence and the actual date of transfer or transmission of such assets . However, it is paradoxical that Spanish capital gains taxation is not guaranteed with respect to possible transfers of the actual centre of administration to other States that have signed agreements on double taxation with Spain containing a clause similar to art.
Exit taxes and the transfer abroad of goods and rights from the parent company in Spain. Regardless of whether the taxation we are referring to responds to the internationally accepted principle of separate company, established by art. Indeed, according to art. In these cases, the inclusion of the difference between the market value of transferred goods or right and its acquisition for the parent company is, in our opinion justified, although, as the Commission indicates, the taxation should probably be differed to the time of transfer to a third party .
Again, in our opinion, these are problems to be solved only by legislative procedures, although the mutual recognition of values, as the Commission proposes, could be an adequate way. In taxation terms, the loss of fiscal residence of SE or ECS in Spain or the transfer of assets to their PEs abroad will determine the application either of art. In this sense, it can be said that the special regulation of the transfer of address of SE or ECS in the art. The same thing will happen when the transfer of assets from SE or ECS to their PEs located in other Member States generates a fictitious income that should be included in corporate tax returns in the tax year in which the transfer was carried out.
Lefebvre, David Marrani . To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. Mondaq may alter or amend these Terms by amending them on the Website. These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms.
If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident "Local Law". In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.
Rather, any such waiver or release must be specifically granted in writing signed by the party granting it. If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.
Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.