Proposal for an Enhanced CCTB as Alternative to a CCCTB with Formulary Apportionment
- E. Röder
- World Tax Journal, 2012 (Volume 4), No 2
- 21 May 2012
Replacing separate accounting and the arm’s length standard by consolidation and formulary apportionment lies at the heart of the Commission’s proposal for a Common Consolidated Corporate Tax Base. This article shows that such a radical change of system is not justified as it would not solve the problems related to the arm’s length standard, but would combine them with additional drawbacks of consolidation and formulary apportionment. The article instead pleads for an enhanced Common Corporate Tax Base without consolidation as an alternative approach for the reduction of tax obstacles to the internal market.