BEFIT: A Blast From the Past or a Modernized Approach to Tax Simplification?

In this note, the author discusses the Draft “Business in Europe: Framework for Income Taxation (BEFIT)” proposal and its mechanics. Apart from providing an overview of how the draft Directive is expected to operate, attention is given to the regime applicable to cross-border tax loss relief and the differences and potential similarities between BEFIT and prior similar attempts of the European Commission – namely the Common (Consolidated) Corporate Tax Base proposals.