CCCTB and Business Reorganizations The Common Consolidated Corporate Tax Base and Business Reorganizations

Business reorganizations that involve at least one Common Consolidated Corporate Tax Base (CCCTB) group can be a complex topic to draft legislation in. This is especially true when it comes to the fiscal treatment of trading losses and hidden reserves in the transition from a national tax system to consolidation under the CCCTB rules and vice versa. To prevent distortions and practices of tax avoidance, a line has to be drawn, so that losses and underlying values are allocated to the period of time during which they were generated. In addition, it will be politically crucial that policy-making is guided by a balanced approach to state sovereignty and the objectives for market integration in the EC.