The Resource Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning

Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning

Label
Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning
Title
Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning
Creator
Subject
Language
eng
Summary
The common consolidated corporate tax base (CCCTB) regime proposed by the European Commission has the potential to tackle most of the key issues of international taxation. However, there is an inherent flaw in the design of the CCCTB. The system does not remove the incentive of Member States to engage in tax rate competition. On the other hand, the CCCTB leaves multinational enterprises (MNEs) with the opportunity for tax minimization through shifting of real activities. This article introduces an amendment to the CCCTB that would tackle these structural defects. The approach presented in this article is to include in the formulary apportionment system of the CCCTB an additional calculation method, namely the destination-with-credit formula. The article first explains the basic structure, merits and flaws of the CCCTB proposal (section 2.), describes and evaluates previously outlined solutions to the shortcomings of the CCCTB (section 3.) and presents the destination-with-credit approach (section 4.)
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 47 (2019), no. 5 ; p. 490-495
http://library.link/vocab/creatorName
Nieminen, M
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • CCCTB
  • tax competition
  • formulary apportionment
  • corporate income tax
  • MNE
Label
Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning
Instantiates
Publication
Label
Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning
Publication

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