The CCCTB aims to provide a common system for calculating the tax base of corporate groups operating in the EU and to deal with only the tax administration in the country where their registered office is established. This means that EU companies would benefit from a 'one-stop shop' system for filing their tax returns and would be able to consolidate all the profits and losses they incur across the EU.
ACCA, as a global accountancy body, believes this would provide businesses, and especially SMEs in light of the vital role they play in the internal market, with the right incentives to go international and make the most out of the single market.
Chas Roy-Chowdhury, head of taxation at ACCA says: 'It is a positive step that all companies would have the possibility to opt into the CCCTB system as soon as the Directive comes into force. We agree with rapporteur Thyssen that this should lead to greater fiscal transparency, improve the prospects for growth of businesses with cross-border operations, while making the EU more attractive to foreign investors.'
Chas Roy-Chowdhury adds: 'It seems also reasonable to go beyond the European Commission’s proposal and to support the MEP’s roadmap approach asking the CCCTB regime should become mandatory for all transnational companies after two years, and after five years to all companies operating in European territory. MEPs also rightly decided to exempt SMEs from the automatic application of that common tax base, while giving them the option to use it should they wish to, as they need more flexibility.
'ACCA also agrees this should not, nevertheless, represent an overture to harmonisation of corporate tax rates in member states, the latter rightly retaining the power to adopt certain advantages to enterprises, such as in the form of tax credits.'
However, the discussions are far from being over, and parties involved need to be realistic regarding the existing resistance from certain member states fearing amongst other things a loss of sovereignty and of tax revenues. The European Commission will still have to obtain the unanimous agreement of the Council which is likely to be much more difficult.
'ACCA hopes the stalemate in the Council can be unlocked rapidly, as the CCCTB will be very useful to address the underlying legal and tax obstacles - such as double taxation - which exist for companies operating in more than one member state. The use of the enhanced cooperation suggested by MEP Thyssen could be an option to consider,' Chas Roy-Chowdhury concluded.