Corporate Income Taxation in Europe The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries
The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries
Edited by Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck
Chapter 1: Taxation of EU resident companies under the current CCCTB framework: Descriptive and critical approach to selected ‘extraterritorial’ aspects
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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