The future of domestic and European group taxation is widely debated in political and business circles, as well as in the academic world. This article addresses the numerous political and systematic issues of group taxation through a three step approach. First, it defines the diverse fundamental...

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...

To this date, the European Union (EU) has not been very successful in implementing any serious cooperation or harmonization in corporate taxation. The European Commission (EC) for instance already called for a harmonization of corporate tax systems, bases and rates, in the 1960‟s. Subsequently...

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...

Replacing separate accounting and arm's length pricing by consolidation and formulary apportionment lies at the heart of the Commission's proposal for a Common Consolidated Corporate Tax Base. This article shows that such a radical change of system is not justified as it would not solve the...

This paper provides an assessment of the potential consequences for average corporate tax rates that would result from implementation of a Common Consolidated Corporate Tax Base (CCCTB) as proposed by the European Commission, and of possible methods for achieving an EU-wide loss-offset for...

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 Great Financial Crisis has increased concerns about whether corporations are paying a ‘fair' amount of tax in different countries. This begs the question of what a ‘fair' amount of tax is. The question is complicated by the continuing lack of clarity about the economic incidence of...