Tax neutrality and business financing in a post BEPS/ATAD/ corona world

Barone, Gabriele (A.A. 2020/2021) Tax neutrality and business financing in a post BEPS/ATAD/ corona world. Tesi di Laurea in European taxation, Luiss Guido Carli, relatore Federico Rasi, pp. 239. [Single Cycle Master's Degree Thesis]

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Debt and equity financing. Overview of debt and equity. Taxation rules for income from capital: interests and dividends. Policy aspects. Direct and indirect incentives to equity financing. The anti-tax avoidance directive. The Italian regime for the deductibility of interest expenses. Final remarks on the interest limitation rule. Allowance for corporate equity (ACE). Fundamental proposals to eliminate the debt-equity bias. The consistency of the interest limitation rule: between EU primary law and constitutional law. Possible breach of the principle of proportionality. Concluding remarks on a European and international perspective. The principle of ability to pay.


Bibliografia: pp. 228-239.

Thesis Type: Single Cycle Master's Degree Thesis
Institution: Luiss Guido Carli
Degree Program: Single Cycle Master's Degree Programs > Single Cycle Master's Degree Program in Law (LMG-01)
Chair: European taxation
Thesis Supervisor: Rasi, Federico
Thesis Co-Supervisor: Silvestri, Andrea
Academic Year: 2020/2021
Session: Summer
Deposited by: Alessandro Perfetti
Date Deposited: 20 Jan 2022 08:10
Last Modified: 20 Jan 2022 08:10


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