Brussels, 08/10/2015 (Agence Europe) - On Thursday 8 October, the European Commission announced a public consultation to feed into its reflection on the common consolidated corporate tax base (CCCTB), which it hopes to relaunch before the end of 2016.
The Commission is seeking the views of the stakeholders on the following questions: - to what extent could the CCCTB function as an effective tool against aggressive tax planning, without compromising its initial objective of making the single market a more business-friendly environment? - Which criteria should determine the companies which will be subject to the rules of a mandatory CCCTB? - Should there be possibilities for exemptions ('opt out')? - How is the 'staged' approach called for by the Commission (which consists of putting the 'consolidation' part of the proposal, the main sticking point at the Council, off until a later date) perceived? - Would it be useful, in the short term, to agree common rules for the common tax base in order to implement certain international aspects of the OECD's BEPS action plan (base erosion and profit transfer; see EUROPE 11403), based on the current proposal until the Commission adopts a new proposal by the end of 2016?- How should the debt equity bias problem be treated? - Which types of rules would best foster research and development activity? - Should there be an interim mechanism for the cross-border compensation of losses for businesses until there is full consolidation?
These are the questions the Commission had already raised in the framework of its action plan on the fight against aggressive tax planning, which was presented in June (see EUROPE 11331 and 11332).
Amongst other things, the public consultation aims to shed light on the concerns of the business world and NGOs regarding any postponement of the 'consolidation' aspect. BusinessEurope and various NGOs are already calling for the Commission to reconsider this postponement (see EUROPE 11377). BusinessEurope would also prefer the CCCTB to remain optional, as per the Commission's initial proposal. On the question of the 'debt equity bias', the EU should be able to build on the OECD's BEPS action plan, which makes recommendations.
According to the organisation ACCA, which represents European accountancy experts, enhanced cooperation will probably be the final outcome. “Unanimity in the Council is very unlikely to succeed”, said its head of taxation, Chas Roy-Chowdhury. The Commissioner for Taxation, Pierre Moscovici, has also broached this issue in the past.
The public consultation will run until 8 January 2016. (Original version in French by Elodie Lamer)