What do politicians think of the common consolidated corporate tax base? A Belgian case study

This paper analyzes the views of Belgian politicians on the Common Consolidated Corporate Tax Base (CCCTB), an ambitious project to harmonize corporate taxation in the EU. Applying case study methodology, the results show that most politicians were proponents of this new tax system. During the discussions in several political institutions, the politicians referred to the macro-economic impact, the legal certainty and their party’s view to found their opinion. Besides several agreements, certain aspects of CCCTB like the optionality and the applied tax rate involved clear differences in view between left and right-wing politicians, which could hamper a political agreement on CCCTB

Essays on the harmonization of the corporate tax system in Europe

The current rules for corporate taxation in Europe do not longer fit the globalized economic activities. Taxing corporate income on a national level leads to many tax obstacles for European multinationals. European multinationals, for example, face high compliance costs, suffer limitations to cross-border loss compensation and have to deal with transfer pricing issues. In an attempt to provide a comprehensive solution for the underlying tax obstacles that currently harm the international competitiveness of European multinationals, the European Commission (EC) launched a proposal for a Common Consolidated Corporate Tax Base directive (EC, 2011). The proposal includes one set of tax rules, allowing multinationals to calculate a common consolidated corporate tax base on a group level. The consolidated tax base would then be reapportioned to the different group members by means of an apportionment formula, which includes the factors active, sales and labour. The Member States preserve the right to apply their own tax rate to their specific share of the consolidated tax base. This dissertation contributes to the rather limited academic research concerning CCCTB. The core aims are (i) to explore the design of the European apportionment formula, (ii) to investigate the EU apportionment formula regarding the role of intangible assets in Belgium and (iii) to attain insights in the voting behaviour of the Members of the European Parliament (MEP). In the first study we focus on the design of the European apportionment formula, which plays a major role in Member States’ concern for protecting their tax revenue, as well as for the multinational companies’ tax minimizing opportunities. More specifically, we investigate the effect of changing the number of factors that make up the formula and the weight given to each factor. We used unpublished firm level data from a listed multinational, which enabled us to study the factor definitions in detail. Our simulation results indicate that including more factors and applying more equal weights distributes the consolidated tax base more equally, which reduces tax planning opportunities. Moreover, for our multinational, using more simplified factors definitions does not change the allocation of the consolidated tax base to a great extent. This advocates the inclusion of simplified factor definitions to reduce the compliance costs for multinationals. In the second study we focus on the factor assets in the apportionment formula. Namely, it is the commission’s intention to only partly and temporarily include intangible assets into this factor. The main reason for this is that the inclusion of intangibles could create tax planning opportunities for multinationals caused by location and valuation issues. However, excluding intangible assets from the apportionment formula could lead to an unfair distribution of the consolidated tax base. Member States that invest highly in a more knowledge-based economy, would lose taxable income they are entitled to. We empirically investigate this issue in a Belgian context. More precisely, using firm specific data from the Belfirst database, we investigate the profit generating capacity of both the proposed allocation factors, i.e. tangible fixed assets, sales and labour, as well as the additional allocation factor, viz intangible assets. Our results show that intangible assets, defined as the sum of ‘capitalized R&D costs’ and ‘concessions, patents and licences’, have a significant and positive impact on the creation of profit. We also include the factor capitalized R&D costs separately and find a positive and significant contribution of this factor to the generation of profit. In addition, our results show both the formula adding intangible assets to the proposed allocations factors, and the formula adding capitalized R&D costs, perform significantly better than the formula only including the proposed factors. Moreover, the formula adding intangible assets is more precise in explaining profit than the formula including capitalized R&D costs. The proposal for a CCCTB directive concerns a decision about direct taxation, meaning that the consultation procedure is applied. This procedure implies that the final decision rests with the Council of the EU and that the European Parliament plays a consultative role. In April 2012, the Member of the European Parliament approved the amended CCCTB proposal (452 votes in favour, 172 against and 36 abstentions). The third study gives insight into the voting behaviour of MEPs concerning the CCCTB directive. We focus on the question whether or not the voting behaviour of MEPs is influenced by the economic impact of CCCTB for their country. The economic impact of CCCTB is measured through the impact of CCCTB for each MS on their corporate income tax revenue. We collected the voting results from the independent organization VoteWatch Europe. Our results show that a higher impact of CCCTB on the corporate income tax revenue, increases the likelihood of a MEP to vote in favour of the proposal. As a robustness check we also measured economic impact by using the impact on employment and GDP. Again, we find that MEPs are significantly and positively influenced in their voting behaviour by the impact of CCCTB on employment and GDP for their country. Finally, we find that political party and country variables also have a significant effect on the voting behaviour of MEPs, whereas the individual characteristics of MEP did not have a significant influence

Inhalation anesthesia with isoflurane in a black jaguar (Panthera onca) for surgical repair of a fractured mandible

A black jaguar (Panthera onca) was anesthetized with a combination of medetomidine, ketamine and isoflurane in oxygen for radiological examination and surgical repair of a fractured mandible. Since a non-domesticated cat is potentially dangerous, induction of anesthesia was performed by intramuscular injection using a mechanical squeeze cage. The cardiopulmonary parameters during anesthesia remained within normal ranges; only a small increase in the respiration rate was recorded 75 minutes after intubation. This hyperventilation was treated with buprenorphine (for additional analgesia) and an increased inspiratory fraction of isoflurane. Recovery was rather slow after 165 minutes of general anesthesia, so atipamezole was administered. Ten minutes after the intramuscular injection of atipamezole, the animal started to recover. Meloxicam and buprenorphine were used for post-operative analgesia

A paleolimnological reconstruction of mid and late holocene climate change in South Georgia

South Georgia is located at the barrier between Antarctica and the mid-latitudes which makes it a key location to determine the main drivers of past and present-day climate variability and to assess whether the climate in the South Atlantic was synchronous with Antarctica or South America. Here we performed a sedimentological, high resolution (ITRAX) geochemical, and fossil diatom and pigment analysis of a 5.41 m long, ca. 8000 cal yr BP, sediment core from Fan Lake, Annenkov Island, South Georgia (54°29’0’’S, 37°5’0’’W) in an attempt to separate the influence of Holocene palaeoclimatic variability from changes in catchment stability and glacier activity. While radiocarbon ages of events in the top 250 cm (c. 4 ka) of this core appear to be broadly in line with some other studies on South Georgia, the chronology of the lower half still poses several questions. The main lithological division in the profile is marked by the establishment of finely laminated sedimentation at c. 250 cm (4000 yrs BP) and is also picked out by the diatom and pigment analysis. This change is characterized by a reduction to low stable magnetic susceptibility values and a step-change increase in organic matter, and is most likely related to deglaciation of the lake catchment during the ‘Mid Holocene Hypsithermal’. Although the diatom composition is dominated by a single species (i.e., Cyclotella stelligera), relatively minor, but sometimes significant, fluctuations in other diatom species occur in the top 250 cm (mid-late Holocene). Interestingly, the most remarkable change in the diatom record occurs at c. 100 cm (1000 cal yr BP) and coincides with an increase in general lake productivity. We link these changes to increased catchment disturbance at c. 1000 cal yr BP, which is possibly associated with deglaciation following one of four relatively minor ‘post-cooling events’ during the late Holocene

Late quaternary climate history of Heart Lake and Pup Lagoon (Larsemann Hills, East Antarctica)

Information on East-Antarctic coastal environments during the Holocene is relatively sparse. This is surprising as sedimentary records from the interface between land and sea can provide chronologies of climate change, isostatic uplift, relative sea level and the colonisation of newly formed biomes. Here we examine a sediment core from Pup Lagoon and Heart Lake (Larsemann Hills, East Antarctica). Sediment stratigraphy, fossil pigments and diatoms were used to infer the sequence of Holocene environmental and climate change. Results show that between 5800 and 4785 corr. yr BP the marine coast of Prydz bay was characterized by stratified, open water conditions during spring and summer and seasonally warm conditions. From 4785 to 2615 corr. yr BP sea ice duration in Prydz Bay increased with the coast being ice-free for 2-3 months each year, conditions which are similar to the present day. A return to stratified, open water conditions and a reduction in winter sea ice extent between 2615 corr. yr BP - 2200 uncorr. yr BP is signaled by enhanced biogenic production and more open water diatom taxa

Patrick Dendale, éd., « Le mouvement dans la langue et la métalangue », Recherches linguistiques, 27

À l’heure actuelle, la perspective cognitive-fonctionnelle sur le langage constitue l’une des approches dominantes en linguistique. Au sein de ce « paradigme », les concepts spatiaux, et la relation entre ceux-ci et des notions plus abstraites comme le temps, sont particulièrement importants. C’est ce dont témoigne le présent volume, édité par Patrick Dendale, dans lequel toutes les contributions se penchent d’une façon ou d’une autre sur le problème du mouvement, que ce soit au niveau de son..