In October 2016, the Commission proposed to re-launch the Common Consolidated Corporate Tax Base.
The re-launched CCCTB will be implemented through a two-step process and will be mandatory for the largest groups in the EU.
What is the Common Consolidated Corporate Tax Base (CCCTB)?
The Common Consolidated Corporate Tax Base (CCCTB) is a single set of rules to calculate companies' taxable profits in the EU.
With the CCCTB, cross-border companies will only have to comply with one, single EU system for computing their taxable income, rather than many different national rulebooks.
Companies can file one tax return for all of their EU activities, and offset losses in one Member State against profits in another.
The consolidated taxable profits will be shared between the Member States in which the group is active, using an apportionment formula. Each Member State will then tax its share of the profits at its own national tax rate.
What are the benefits of the CCCTB?
The CCCTB is a modern, fair and competitive corporate tax framework for the EU.
In particular, it will:
Improve the Single Market for businesses
The CCCTB will reduce red tape and cut compliance costs for companies in the Single Market. It will provide a single EU system for companies to calculate their taxable income and a "one stop shop" to file a tax return for all their EU activity.
The CCCTB will fully recognise companies' cross-border activities in the Single Market. It will allow companies to offset profits in one Member State against losses in another. This is particularly important for small and start-up companies.
The CCCTB will provide companies with legal certainty and reduce tax obstacles, by providing a single, stable, transparent corporate tax system for the EU.
Combat tax avoidance
The CCCTB will be mandatory for the largest groups in the EU. This will prevent companies with the greatest capacity to tax plan from avoiding taxation.
The CCCTB will eliminate mismatches between national systems, preferential regimes and hidden tax rulings, which tax avoiders exploit. It will remove the need for transfer pricing, which is a primary route for profit shifting.
The CCCTB contains robust anti-abuse measures, to defend Member States against base erosion and profit shifting to non-EU countries.
Support growth, jobs and investment in the EU
The CCCTB can lift investment in the EU by 3.4% and growth by up to 1.2%.
It will encourage business and investment, by offering companies solid and predictable rules, a fair and level-playing field, and reduced costs and administration.
It will incentivise R&D spending, which is crucial for growth, with a super-deduction.
It will remove the current debt-bias in corporate taxation, by rewarding equity financing. This will support a strong Capital Markets Union and EU financial stability.
Re-launching the CCCTB
The Commission had originally proposed the CCCTB in 2011, but that proposal proved too ambitious for Member States to agree in one go.
However, there was still strong demand for the benefits that the CCCTB could offer to Member States and businesses in the EU.
Therefore, the Commission re-enforced the original CCCTB proposal and re-launched it through a more manageable process.
The key changes in the re-launched CCCTB are:
The CCCTB will be implemented in two steps
In the first step, the common base should be implemented. Consolidation should be put in place swiftly afterwards.
The CCCTB will be mandatory for large multinationals
The original CCCTB proposal was optional for all companies and groups of companies. The re-launched CCCTB system will be mandatory for large groups, to cover those with the greatest capacity to tax plan. The system will remain optional for those not captured by the mandatory scope.
The CCCTB will give strong incentives to R&D
The CCCTB now includes a new super-deduction for companies that invest in R&D spending, given the importance of such investment for growth and jobs.
The CCCTB will encourage stable financing
The CCCTB will give companies similar benefits for equity financing to what they currently get for debt financing, to address the debt-bias in taxation and encourage more solid financing structures and greater economic stability.
- Press Release
- Question & Answers (MEMO)
- 2016 proposal on Common Tax Base - Annex
2016 proposal on Consolidation - Annex
- 2016 Impact Assessment - Impact assessment summary
The 2011 CCCTB PROPOSAL