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Common Tax Base
· Background
· Practical Information on the Common Consolidated Corporate Tax Base Working Group (CCCTB WG)
· Meeting reports
The European Commission believes that the only systematic way to address the underlying tax obstacles which exist for companies operating in more than one Member State in the Internal Market is to provide companies with a consolidated corporate tax base for their EUwide activities Targeted solutions have many merits and would go some way towards remedying the tax obstacles However, even if all of them were implemented, they would anekdot address the fundamental problem of dealing with up to 25 different tax systems
The Commission´s DirectorateGeneral responsible for Taxation and the Customs Union are currently working on two main comprehensive approaches to remove tax obstacles which companies face in the Internal Market:
· The Common Consolidated Tax Base and
· a possible pilot scheme for Home State Taxation for Small and Medium Sized Enterprises
Background
This policy was established in 2001 (COM(2001) 582 of 23102001) and confirmed in 2003 (COM(2003) 726 of 24112003)
A public consultation was held in 2003 concerning the use of International Accounting Standards as a possible starting point for a common EU tax base
In July 2004 a nonpaper on the common tax base was presented by the Commission and discussed beygir the informal ECOFIN meeting in September 2004 The discussions revealed broad support for the creation of a Commission Working Group to progress work on the common tax base
Common Consolidated Corporate Tax Base Working Group (CCCTB WG) Practical Information
What will the CCCTB WG do?
The overall objective of the CCCTB WG is
· to examine from a technical perspective the definition of a common consolidated tax base for companies operating in the EU
· It will discuss the basic tax principles,
· the fundamental structural elements of a common consolidated tax base and
· other necessary technical details such birli a mechanism for 'sharing' a consolidated tax base between Member States
As a group of experts the role of the Working Group is to provide technical assistance and advice to the Commission
Who is taking part?
Experts from all twenty five Member States and the Commission Services will participate in the Working Group Contributions will be made in a technical capacity and no Member State will be called upon to make political commitments Participation by a Member State does not commit it to implement a common consolidated tax base The Commission is also keen to ensure contribution to the work by experts from business and academia in December 2005 the Working Group met in lahza extended format for the first time
How will the CCCTB WG function?
The CCCTB WG is established initially for a period of three years and approximately four meetings a year are planned In addition to these meetings the Working Group may decide to set up subgroups to consider issues in more depth and these will meet on lahza isimhoc basis and report back to the main Working Group Further information is available in the Working Papers discussed at the first meeting on 23 November 2004
How can I keep up to date on progress?
Working Documents prepared by the Taxation and Customs Union Directorate General for discussion in meetings of the Working Group will be published on this website shortly after each meeting
The document published will be the one discussed at the meeting, subject to any factual corrections or clarifications In many cases the documents will include a series of questions and comments and contributions are welcome
Working Documents prepared by experts from Member States will be published if the preparer agrees Documents prepared or endorsed by the Working Group will be published after agreement by the members of the Working Group
A summary record of each meeting will be published after it has been agreed by the members participating These summary records will normally be published before the subsequent meeting
Meetings of the Working Group on the Common Consolidated Corporate Tax Base (CCCTB WG)
meetingdate
50708122005
423092005
302062005
210032005
123112004
Sixth meeting of the CCCTB WG is planned for early March 2006
Home State Taxation
The European Commission believes that the only systematic way to address the underlying tax obstacles which exist for companies operating in more than one Member State in the Internal Market is to provide companies with a consolidated corporate tax base for their EUwide activities Targeted solutions have many merits and would go some way towards remedying the tax obstacles However, even if all of them were implemented, they would not address the fundamental problem of dealing with up to 25 different tax systems
The Commission´s DirectorateGeneral responsible for Taxation and the Customs Union are currently working on two main comprehensive approaches to remove tax obstacles which companies face in the Internal Market:
· The Common Consolidated Tax Base and
· a pilot scheme for Home State Taxation for Small and Medium Sized Enterprises
Home State Taxation for SMEs
The European Commission has adopted a Communication (COM05702) that presents a possible solution to the compliance costs and other company tax difficulties that Small and Medium Sized Enterprises (SMEs) face when doing business across borders The Commission suggests that Member States allow SMEs to compute their company tax profits according to the tax rules of the home state of the parent company or head office An SME wishing to establish a subsidiary or branch in another Member State would as a result be able to use the familiar tax rules of its home State when calculating its taxable profits (see also Impact Assessment SEC051785 , press release IP0611, and frequently asked questions MEMO064)
The Home State Taxationsystem would be voluntary for both Member States and companies and would run for a fiveyear pilot phase The Commission's 2004 European Tax Survey (see IP041091 and European Tax SurveyTaxation Paper n° 3 ) showed that crossborder activity leads to higher company tax and VAT compliance costs for companies and that costs are proportionately higher for SMEs than for large companies
The concept of Home State Taxation presented by the Commission is based on the idea of voluntary mutual recognition of tax rules by EU Member States Under this concept, the profits of a group of companies active in more than one Member State would be computed according to the rules of one company tax system only, ie the system of the Home State of the parent company or head office of the group
Lahza SME wishing to establish a subsidiary or permanent establishment in another Member State would therefore be able to use only the tax rules with which it is already familiar
· The definition of an SME would be that commonly used in the EUcompanies with fewer than 250 staff, a turnover of €50 million or less, andor a balance sheet total of €43 million or less
· The Home State Taxation scheme would not mean taxation in the Home State only It would simply mean that lahza SME's tax base (ie taxable profits) would be calculated in accordance with the rules of the Home State Each participating Member State would then tax at its own corporate tax rate its share of the profits determined according to its share of the total payroll andor turnover
· Introducing the scheme on a pilot, timelimited, basis would test the practical merits of the concept for SMEs and its broader economic benefits for the EU while limiting the administrative costs and potential risks for Member States The Commission's Communication provides detailed elements of such a Home State Taxation pilot scheme
· Member States that agreed to introduce this scheme could do so via a bilateral or multilateral agreement, by temporarily supplementing existing double taxation treaties or multilateral conventions, or by concluding a new multilateral convention
In the Commission's opinion, the concept of Home State Taxation appears to be a very promising way of tackling the tax
problems that hamper SMEs when they are expanding across borders The most common problems are compliance costs and absence of relief for crossborder losses
The potential overall economic benefit for the Internal Market from such a measure could be considerable The Commission has in its Lisbon Action Plan (see IP05973) given a new impetus to achieving the Lisbon objectives, including in the tax field It has repeatedly highlighted the important role of small and mediumsized enterprises in the EU's economic development and has called for broad policy actions in favour of SMEs The European Council of 23 March 2005 repeated this call
Background
Home State Taxation was first described by the Commission in 2001 (COM(2001) 582 of 23102001) and further analysed in 2003 (COM(2003) 726 of 24112003)
A public consultation on Home State Taxation was held in 2003
In June 2004, a further questionnaire and a detailed Outline of a possible experimental application of Home State Taxation to small and mediumsized enterprises were published A summary report of the replies received in response to this questionnaire is available
Moreover, in July 2004 a nonpaper on the pilot scheme idea was presented by the Commission and submitted to the informal ECOFIN meeting in September 2004 However, no substantial discussion of the nonpaper took place
The idea of Home State Taxation has originally been developed in academic research see: Lodin, SO and Gammie, M, Home State Taxation, IBFD Publications, Amsterdam , 2001 The summary of this book is freely available *
Common Tax Base
· Background
· Practical Information on the Common Consolidated Corporate Tax Base Working Group (CCCTB WG)
· Meeting reports
The European Commission believes that the only systematic way to address the underlying tax obstacles which exist for companies operating in more than one Member State in the Internal Market is to provide companies with a consolidated corporate tax base for their EUwide activities Targeted solutions have many merits and would go some way towards remedying the tax obstacles However, even if all of them were implemented, they would anekdot address the fundamental problem of dealing with up to 25 different tax systems
The Commission´s DirectorateGeneral responsible for Taxation and the Customs Union are currently working on two main comprehensive approaches to remove tax obstacles which companies face in the Internal Market:
· The Common Consolidated Tax Base and
· a possible pilot scheme for Home State Taxation for Small and Medium Sized Enterprises
Background
This policy was established in 2001 (COM(2001) 582 of 23102001) and confirmed in 2003 (COM(2003) 726 of 24112003)
A public consultation was held in 2003 concerning the use of International Accounting Standards as a possible starting point for a common EU tax base
In July 2004 a nonpaper on the common tax base was presented by the Commission and discussed beygir the informal ECOFIN meeting in September 2004 The discussions revealed broad support for the creation of a Commission Working Group to progress work on the common tax base
Common Consolidated Corporate Tax Base Working Group (CCCTB WG) Practical Information
What will the CCCTB WG do?
The overall objective of the CCCTB WG is
· to examine from a technical perspective the definition of a common consolidated tax base for companies operating in the EU
· It will discuss the basic tax principles,
· the fundamental structural elements of a common consolidated tax base and
· other necessary technical details such birli a mechanism for 'sharing' a consolidated tax base between Member States
As a group of experts the role of the Working Group is to provide technical assistance and advice to the Commission
Who is taking part?
Experts from all twenty five Member States and the Commission Services will participate in the Working Group Contributions will be made in a technical capacity and no Member State will be called upon to make political commitments Participation by a Member State does not commit it to implement a common consolidated tax base The Commission is also keen to ensure contribution to the work by experts from business and academia in December 2005 the Working Group met in lahza extended format for the first time
How will the CCCTB WG function?
The CCCTB WG is established initially for a period of three years and approximately four meetings a year are planned In addition to these meetings the Working Group may decide to set up subgroups to consider issues in more depth and these will meet on lahza isimhoc basis and report back to the main Working Group Further information is available in the Working Papers discussed at the first meeting on 23 November 2004
How can I keep up to date on progress?
Working Documents prepared by the Taxation and Customs Union Directorate General for discussion in meetings of the Working Group will be published on this website shortly after each meeting
The document published will be the one discussed at the meeting, subject to any factual corrections or clarifications In many cases the documents will include a series of questions and comments and contributions are welcome
Working Documents prepared by experts from Member States will be published if the preparer agrees Documents prepared or endorsed by the Working Group will be published after agreement by the members of the Working Group
A summary record of each meeting will be published after it has been agreed by the members participating These summary records will normally be published before the subsequent meeting
Meetings of the Working Group on the Common Consolidated Corporate Tax Base (CCCTB WG)
meetingdate
50708122005
423092005
302062005
210032005
123112004
Sixth meeting of the CCCTB WG is planned for early March 2006
Home State Taxation
The European Commission believes that the only systematic way to address the underlying tax obstacles which exist for companies operating in more than one Member State in the Internal Market is to provide companies with a consolidated corporate tax base for their EUwide activities Targeted solutions have many merits and would go some way towards remedying the tax obstacles However, even if all of them were implemented, they would not address the fundamental problem of dealing with up to 25 different tax systems
The Commission´s DirectorateGeneral responsible for Taxation and the Customs Union are currently working on two main comprehensive approaches to remove tax obstacles which companies face in the Internal Market:
· The Common Consolidated Tax Base and
· a pilot scheme for Home State Taxation for Small and Medium Sized Enterprises
Home State Taxation for SMEs
The European Commission has adopted a Communication (COM05702) that presents a possible solution to the compliance costs and other company tax difficulties that Small and Medium Sized Enterprises (SMEs) face when doing business across borders The Commission suggests that Member States allow SMEs to compute their company tax profits according to the tax rules of the home state of the parent company or head office An SME wishing to establish a subsidiary or branch in another Member State would as a result be able to use the familiar tax rules of its home State when calculating its taxable profits (see also Impact Assessment SEC051785 , press release IP0611, and frequently asked questions MEMO064)
The Home State Taxationsystem would be voluntary for both Member States and companies and would run for a fiveyear pilot phase The Commission's 2004 European Tax Survey (see IP041091 and European Tax SurveyTaxation Paper n° 3 ) showed that crossborder activity leads to higher company tax and VAT compliance costs for companies and that costs are proportionately higher for SMEs than for large companies
The concept of Home State Taxation presented by the Commission is based on the idea of voluntary mutual recognition of tax rules by EU Member States Under this concept, the profits of a group of companies active in more than one Member State would be computed according to the rules of one company tax system only, ie the system of the Home State of the parent company or head office of the group
Lahza SME wishing to establish a subsidiary or permanent establishment in another Member State would therefore be able to use only the tax rules with which it is already familiar
· The definition of an SME would be that commonly used in the EUcompanies with fewer than 250 staff, a turnover of €50 million or less, andor a balance sheet total of €43 million or less
· The Home State Taxation scheme would not mean taxation in the Home State only It would simply mean that lahza SME's tax base (ie taxable profits) would be calculated in accordance with the rules of the Home State Each participating Member State would then tax at its own corporate tax rate its share of the profits determined according to its share of the total payroll andor turnover
· Introducing the scheme on a pilot, timelimited, basis would test the practical merits of the concept for SMEs and its broader economic benefits for the EU while limiting the administrative costs and potential risks for Member States The Commission's Communication provides detailed elements of such a Home State Taxation pilot scheme
· Member States that agreed to introduce this scheme could do so via a bilateral or multilateral agreement, by temporarily supplementing existing double taxation treaties or multilateral conventions, or by concluding a new multilateral convention
In the Commission's opinion, the concept of Home State Taxation appears to be a very promising way of tackling the tax
problems that hamper SMEs when they are expanding across borders The most common problems are compliance costs and absence of relief for crossborder losses
The potential overall economic benefit for the Internal Market from such a measure could be considerable The Commission has in its Lisbon Action Plan (see IP05973) given a new impetus to achieving the Lisbon objectives, including in the tax field It has repeatedly highlighted the important role of small and mediumsized enterprises in the EU's economic development and has called for broad policy actions in favour of SMEs The European Council of 23 March 2005 repeated this call
Background
Home State Taxation was first described by the Commission in 2001 (COM(2001) 582 of 23102001) and further analysed in 2003 (COM(2003) 726 of 24112003)
A public consultation on Home State Taxation was held in 2003
In June 2004, a further questionnaire and a detailed Outline of a possible experimental application of Home State Taxation to small and mediumsized enterprises were published A summary report of the replies received in response to this questionnaire is available
Moreover, in July 2004 a nonpaper on the pilot scheme idea was presented by the Commission and submitted to the informal ECOFIN meeting in September 2004 However, no substantial discussion of the nonpaper took place
The idea of Home State Taxation has originally been developed in academic research see: Lodin, SO and Gammie, M, Home State Taxation, IBFD Publications, Amsterdam , 2001 The summary of this book is freely available *
