Provocările proiectului CCTB/CCCTB. De la suveranitate la armonizare fiscală în Uniunea Europeană
The Challenges of the CCTB/CCCTB Project: From Harmonisation to Tax Integration in the European Union

Summary/Abstract: The regulation on common consolidated tax base CC(C)TB în the European Union (EU) will radically change the company’s taxation, a necessary measure to diminish aggressive tax planning strategies and to eliminate the difficulty în determining transfer pricing. Although the applicability of the territorial source taxation principle will be abolished, the European Commission (EC) proposal for CC(C)TB is welcome în terms of reducing bureaucracy for taxpayers but also for tax authorities. The EC project allocates the consolidated profits of multinationals based on an apportionment formula, based on the volume of sales, the number of employees and the capital invested. We estimate that the effects of the proposal, as amended în the European Parliament în March 2018, are even wider than the recommendations envisaged by the OECD. The final version of CC(C)TB is to be discussed and subject to unanimous approval by the Council of the European Union and the current challenge is to obtain the political agreement. Application of the CC(C)TB will redistribute corporate profits în EU Member States, and some of the founding states will suffer tax revenue losses as part of the taxable profits will be allocated to other states. In our opinion, the CC(C)TB project will only succeed if the proposed calculation method is applied globally, as the effects of the new regulation will occur outside the EU borders

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