principle of territoriality of the tax

principle of the territoriality of the tax

protective principle

principle of extra-territoriality

rule for the territoriality of taxes

principle of territoriality | territorial principle

territorial approach

Appearing: Tony Valeri, M.P., Parliamentary Secretary for the Minister of Finance. Witnesses: From the Department of Finance: Bruce Rayfuse, Senior Chief, International Finance and Economic Analysis Division; Yvon Carrière, Counsel, Tax Counsel Division; Stephen Gagnon, Senior Tax Policy Officer, Intergovernmental Tax Policy Division, Tax Policy Branch; Andrew Treusch, General Director, Federal-Provincial Relations and Social Policy Branch; David Moloney, General Director, Economic and Fiscal Policy Branch; Ted Roseman, Senior Policy Analyst, Social Policy Division; John Manson, Senior Policy Analyst, Social Policy Division; Keith ...[+++] Horner, Senior Chief, Social Tax Policy; Bill Murphy, Tax Policy Officer, Personal Income Tax Division, Tax Policy Branch; Ed Waddington, Senior Policy Analyst, Economic Development and Corporate Finance; Kristina Knopp, Legal Counsel, Brian Willis, Senior Chief, Sales Tax Division Tax Policy Branch, Doug Wyatt, General Counsel.

Assumes that tax increases in certain domains, such as excise duties, could have some positive effects by channelling additional resources, and thus be beneficial to the citizens and the real economy;

Even if the principle of the prudent private investor in a market economy were applicable, in the light of the documents provided by the French authorities shedding light, according to them, on the profit expectations and risks attached to the alleged investment in the form of a tax exemption, application of the test of the private investor in a market economy leads to the conclusion that a prudent private investor would not have invested an amount equal to the tax due in the EDF capital increase in 1997.

In addition, the Commission recalls that as the Court stated (81)‘. whilst the principles of equal tax treatment and equal tax burden certainly form part of the basis of the Spanish tax system, they do not require that taxpayers in different situations be accorded the same treatment ’.