Proposal for a Council Directive on a Common Corporate Tax Base (CCTB)

Key points:


  • endorses the aims of the Commission proposals in the area of the CCCTB and recommends the greatest efforts be made to pursue the CCCTB by consensus, allowing for the sensitive nature of the issues in terms of subsidiarity and state sovereignty;
  • understands the reasons behind the two-stage approach adopted by the Commission but urges the speedy introduction of stage two after the agreement of a common base, as it is only after consolidation that companies will feel the major benefits;
  • recognises that the Commission relaunched the CCCTB proposal both with the objective to aid the single market and to combat aggressive tax planning, attributing income where the value is created;
  • recommends a re-examination of the apportionment formula for the CCCTB. The Commission and the Member States should reflect on whether to exclude intellectual property (IP) from the formulary apportionment;
  • is concerned that the operation of the proposed sales key will result in many of the smaller exporting Member States losing substantial amounts of taxable income to the larger consuming Member States and firmly believes the proposal should aim for an equitable formula and to avoid systematically unbalanced effect;
  • urges caution on the proposals on depreciation to ensure they reflect the real experience of businesses as depreciation allowances may be too limited for certain asset classes subject to very rapid obsolescence due to the pace of technological change;
  • welcomes the recognition of the tax treatment of equity financing for corporate investments, through the proposal to put debt and equity financing on an equal footing;
  • recommends that there should be an equitable balance among Member States as a result of the proposals and thus their impact should be examined in detail on a Member State by Member State basis, in terms of investment attractiveness, job retention and creation;
  • urges the Commission to address the need for flexibility and ensure that states and companies are able to respond to changing global or domestic economic circumstances, while respecting EU procedures and joint cooperation.