Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?

摘要: In March 2011, the European Commission submitted a proposal for Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under currently existing of separate accounting might be replaced by group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face decision as to whether opt system. Prior research focuses mainly differences in economic behaviour both systems general. By contrast, we study conditions which one or other is preferable from perspective MNG, with particular focus loss-offsets. We identify four effects that determine MNG: tax-utilization losses, allocation base, dividend intragroup interest taxation. find mixed results, e.g., proves advantageous increasing loss/profit streams (e.g. start-ups R&D projects) individual entities, whereas beneficial decreasing profit/loss caused decrease return mature product). The results our analysis are helpful MNGs facing can also support legislators politicians EU but regions their reform discussions.