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 5: CCCTB and fiscally transparent entities: A third countries’ perspective

Yariv Brauner

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


The CCCTB project is moving away from an unstable situation: being on the cusp between tax competition and cooperation and coordination of tax policies, the frontline in the battle between proponents of tax competition and of harmonization. Therefore, despite being a purely European creature, the CCCTB carries with it an importance far beyond Europe and European tax policy. At its core, it takes a position in support of political transparency, fairness and humility, representing a daring and novel tax policy initiative that focuses on the people, the constituency. Of course, peripherally, it also has political implications, primarily within Europe. The general goal of CCCTB is to ameliorate, if not eliminate, undesirable tax competition and waste that are based on differences in tax rules rather than directly in tax rates. These differences often result in over or under-taxation due to, for instance, qualification conflicts that are difficult to solve and often are not – even when modern tax treaties apply. Unfortunately, these differences are also mostly not a consequence of intellectual or ideological differences between tax systems. Rather, it is more often that history, arbitrariness and incongruous political circum- stances led to their existence. Yet, more specifically, the CCCTB “aims to tackle some major fiscal impediments to growth in the Single Market,” such as over and under-taxation (often referred to as “double taxation” or “double non- taxation”), and the costs of compliance and administration of taxes in Europe. Here again, the tension between competition and harmonization is apparent.

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