Corporate Income Taxation in Europe

Corporate Income Taxation in Europe

The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries

Edited by Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck

This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.

Chapter 1: Taxation of EU resident companies under the current CCCTB framework: Descriptive and critical approach to selected ‘extraterritorial’ aspects

Edoardo Traversa and Charles-Albert Helleputte

Subjects: law - academic, corporate law and governance, european law, tax law and fiscal policy, law -professional, corporate law


The Common Consolidated Corporate Tax Base (the ‘CCCTB’) is probably the most controversial and often-discussed topic in European direct tax circles in the last decade. Intensively prepared at EU Commission level, firmly opposed by some Member States whilst more or less mildly endorsed by others, commented on by academics and lobbied by business organizations, much has already been said regarding which characteristics such a system should have and about its alleged benefits. The proposal for a Council Directive on a Common Consolidated Corporate Tax Base issued by the EU Commission in March 2011 (the ‘CCCTB Proposal’) is discussed at Council level and it is not a secret to disclose that political agreement is far from being reached. However, recent Eurozone crises and the dissemination of the idea of European economic government suggested by the Sarkozy-Merkel couple have reinforced the political commitment for such a system to be adopted rapidly, even at a non-EU wide level, whether in the form of enhanced cooperation or even using bilateral or multilateral mechanisms outside the European Union framework. The CCCTB is far-reaching and complex. The purpose of this chapter is to provide both a descriptive and, more importantly, critical approach to selected aspects of the CCCTB Proposal. Whilst we will recall, very briefly, the background and main characteristics of CCCTB, this chapter only addresses the extraterritoriality aspects of CCCTB, i.e., the treatment (and possible issues) of income from non-EU sources earned by resident taxpayers.

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