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 9: CFC rules within the CCCTB

Christiana HJI Panayi

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


On 16 March 2011 the Commission published the eagerly awaited final proposal for a Council Directive on a Common Consolidated Corporate Tax Base (“draft CCCTB Directive”) and a detailed impact assessment. The CCCTB is a proposal to provide companies with establishments in at least two Member States with the opportunity to compute their group taxable income according to one set of rules, those of the new consolidated tax base, rather than according to the national tax bases of each Member State. The overall aim of the CCCTB is to reduce the costs of complying with 28 tax regimes, to minimize tax arbitrage and to simplify restructurings. It is also aimed at providing comprehensive consolidation of profits and losses on an EU basis. In other words, the CCCTB is essentially a 29th system. As the Commission stated in its press release on publishing the draft proposal, the aim of it is to significantly reduce the administrative burden, compliance costs and legal uncertainties that businesses in the EU currently face by having to comply with up to 27 (at the time) different national systems for determining their taxable profits. The Commission extolled the proposal, in that it would offer companies a “one-stop-shop” system for filing their tax returns, as well as providing consolidation. It was estimated that on a yearly basis the CCCTB would translate into savings in compliance time and costs. It was also claimed that the new system would bring tangible benefits for companies wishing to expand into other Member States.

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