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...

The current system of taxing the income of multinational firms in the United States is flawed across multiple dimensions. The system provides an artificial tax incentive to earn income in low-tax countries, rewards aggressive tax planning, and is not compatible with any common metrics of...

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...

The essay introduces the main dilemmas faced by decision makers in the European Union (EU) regarding the initiation of a Common Corporate Tax Base (CCTB) in the EU. It introduces the policy considerations and conflict of interests among EU Members, which prevented the initiation of a CCTB in the...

This paper evaluates the Common Consolidated Corporate Tax Base (CCCTB) recently proposed by the European Commission. We find that if the CCCTB is introduced as it is currently proposed (including loss consolidation), then it is likely to impose large tax revenue costs of about one fifth of the...

Corporate Taxation, Group Debt Funding and Base Erosion' is the first in-depth analysis of the features and implications of the directive, and it provides insightful and practical discussions by experts from around Europe on the crucial interactions of the Anti-Tax Avoidance Directive (ATAD)...