The European Commission is currently working on a legislative draft to harmonise corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a set of rules...

The European Commission proposed to replace the currently existing Separate Accounting by an EU-wide tax system based on a Common Consolidated Corporate Tax Base (CCCTB). Besides the CCCTB, there is an alternative tax reform proposal, the European Tax Allocation System (ETAS). In a dynamic...

The European Commission is currently working on a legislative draft to harmonize the corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a Common...

This paper explores how the Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal under the EU law should be designed to allocate cross-border income earned from MNE taxpayers of the transportation industry.The transportation activity is mobile in nature, and thus creates the...

The fact that direct taxation in the EU is still not integrated, and maybe will never be fully integrated, is one of the major obstacles for the 'single market'. The essay describes the history of attempts (and failures) to harmonize direct taxation in the EU - fully or partly. It concentrate on...

Common Consolidated Corporate Tax Base (CCCTB) is an ambitious tax reform project under EU law, to harmonize corporate income tax base on a group basis at the EU level, and use a pre-determined formulary apportionment mechanism (i.e. a formula consisting the sales factor, the asset factor and...

This working paper reviews key elements of the debate around the Commission's proposals to tackle the problem of low effective tax rates for multi-national companies by instituting a Common Corporate Tax Base (CCTB). The paper begins with a non-technical discussion of the main issues, including...

Tax avoidance by multinational enterprises (MNEs) is a global problem. Most cross-border trade occurs within MNEs, susceptible to abuse of gaps and loopholes in domestic and international tax law that allow “profit shifting” between fiscal jurisdictions in order to reduce corporate tax...

The oil and gas industry is an important industry for several European countries. Due to the uniqueness of the industry, there have been special corporate taxation rules for the oil and gas industry where jurisdiction adopts formulary apportionment rules for levying cross-border corporate...