The CCCTB Concept of Consolidation and the Rules on Entering a Group

The consolidation element is at the heart of the proposed Directive on a harmonized Common Consolidated Corporate Tax Base (CCCTB). In this article, the author examines the scope of the consolidation concept. When a company enters a consolidated group, conflicts of interest arise between Member States. These arise as a consequence of the shift from 'separate accounting' to the apportionment formula regime. The author also discusses the measures provided for by the draft Directive to protect the financial interests of Member States.