The common consolidated corporate tax base - issues for Member States opting out and third countries

In this article, the author considers how the Common Consolidated Corporate Tax Base (CCCTB) could affect jurisdictions that are outside the regime, whether Member States or third countries. In this respect, particular emphasis is placed on the position of non-CCCTB Member States, i.e. Member States that opt out of the CCCTB. The article specifically examines the general benefits of consolidation, the proposed rules on the taxation of inbound and outbound investment, and some anti-abuse issues.