1. Re-launch of the Common Consolidated Corporate Tax Base (CCCTB)
Uwe IHLI
Head of Sector, Corporate Tax Directives and Common Consolidated Corporate Tax Base, TAXUD

2. What is the CCCTB?
A common EU tax base that is mandatory (in the 2011 proposal as an option for all companies) for internationally active groups
The consolidation of different tax bases
Appropriate apportionment of tax base to Member States
Member States are free to set rates on their share of consolidated tax base

3. Objectives for the CCCTB (re-launch)
Reducing administrative burden
Simplifying the Single Market for business
Facilitate cross-border activity for companies resident in the EU
AND
A framework for a fair and efficient taxation of corporate profits
Tackling aggressive tax planning
Ensuring that income is taxed where value is created

4. Implementation in stages
Two new proposals under preparation
A Common Corporate Tax Base (CCTB) – first step
Elements related to consolidation added in a second step = CCCTB
In parallel the currently pending proposal will be withdrawn.
The work undertaken in Council on the International aspects of the current CCCTB (document 14544/14) is - to a major extent - reflected in the ATA Directive.

5. What is new?
The CCTB will need to reflect the provisions proposed in the ATA Directive and the work in Council during the last 4 years on
Controlled Foreign Company (CFC legislation) including Switch-over rules
General Anti-Abuse Rule (GAAR)
Interest Limitation rules
Exit taxation

6. What is new? (cont'd)
Possible new provisions included in the public consultation from (closed on ):
Hybrid Mismatch rules
Treatment of Cost for Research and Development
Tackling the Debt Equity Bias
Cross-border Loss Relief

7. What is new? (cont'd)
More than 170 contributions received in the public consultation
Currently analyzed by the colleagues in DG TAXUD
Responses and the report/summary on the public consultation probably made public end of February

8. Open issues for European banks within the CCTB
Specific Interest limitation rule for Banks?
Treatment of hybrid regulatory capital within the hybrid mismatch rules?
CFC legislation in respect to third countries (Carve-out for finance and insurance industry)?
Sector-specific [bad] debt provisions?

9. CCCTB in the Commission Work Programme 2016
Corporate Tax Package - Following up on the Communication on A fair and efficient corporate tax system in the European Union: 5 key areas for action, the package includes a set of measures to enhance transparency of the corporate tax system and fight tax avoidance, including by implementing international standards on base erosion and profit shifting, and a staged approach starting with a mandatory tax base (REFIT) together with withdrawal of the existing CCCTB proposal.
Roadmap for the CCCTB is public.

10. Thank you for your attention!