CC(C)TB and international taxation

Abstract:

On 25 October 2016, the European Commission released two proposals: one on a Common Corporate Tax Base [COM (2016) 685] and one on a Common Consolidated Corporate Tax Base [COM (2016) 683]. If these draft directives (‘the CC(C)TB Drafts’) were to be adopted, they would significantly change the tax landscape for companies operating throughout the European Union as well as for companies which are established in a third country but perform activities within the EU.

The goal of this article is not to provide for an overall description of the features of the CCTB and the CCCTB Drafts. It is rather to give an overview of the main provisions containing a cross-border element and to assess to what extent these new instruments may possibly collide, not only with EU primary law, but also with bilateral (or even multilateral) conventions on double taxation.

ESO: Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) [COM(2016)683] http://www.europeansources.info/record/proposal-for-a-council-directive-on-a-common-consolidated-corporate-tax-base-ccctb-2/

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