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Taxation and Customs Union

Corporate Tax Reform Package

October 2016


Chapeau Communication

Double taxation dispute resolution mechanism

Common Consolidated Corporate Tax Base (CCCTB)

Hybrid Mismatches
with Third Countries

Proposal to amendthe Anti Tax Avoidance Directive

The corporate reform package proposal published on 25th October, 2016 provides three new proposals to provide for a more modern and fairer tax system for business , to close loopholes between EU countries and non-EU countries and to provide new dispute resolution rules to relieve problems with double taxation for buinesses.

More information

Key elements

Common Consolidated Corporate Tax Base (CCCTB)

The Commission has proposed to re-launch the Common Consolidated Corporate Tax Base (CCCTB). The CCCTB will overhaul the way in which companies are taxed in the Single Market, to ensure a fairer, more competitive and more growth-friendly corporate tax system. The re-launched CCCTB will be implemented in two steps. It also contains important new elements to improve its anti-avoidance and growth-promoting capacities.

Double taxation dispute resolution mechanism

The Commission has also proposed an improved system to resolve double taxation disputes in the EU. Double taxation is a major obstacle for businesses, creating uncertainty, unnecessary costs and cash-flow problems. Under the proposal, current dispute resolution mechanisms will be adjusted, to better meet the needs of businesses. In particular, a wider range of cases will be covered and Member States will have clear deadlines to agree on binding solutions to cases of double taxation.

Hybrid Mismatches with Third countries

The package also includes a proposal to extend the rules against hybrid mismatches as provided for in the Anti-Tax Avoidance Directive agreed in June, to hybrid mismatches involving non-EU countries.

Other documents

Press release
Questions and answers
Chapeau Communication on the Corporate Tax Reform Package