Harmonisierung der Konzernbesteuerung innerhalb und an den Außengrenzen der Europäischen Union

In its study on company taxation the European Commission proposed to provide multinational companies with a Common Consolidated Corporate Tax Base (CCCTB) for their EU-wide activities. The application of the CCCTB is limited to the boundaries of the EU. For those cross-border business activities between member states and third countries, separate accounting using arm's length pricing remains. Several issues arise in designing tax rules for cross-border investments involving affiliated companies resident in third countries. This paper investigates options for the tax treatment of non-EU income of EU-resident affiliates and EU income of non-EU-affiliates. It stresses the importance of common tax rules with respect to third countries and discusses different options. However, neither common source based taxation nor common residence based taxation would eliminate tax-induced distortions to business decisions and the international allocation of corporate tax bases across EU countries and third countries.

Spengel, Christoph and Carsten Wendt (2007), Harmonisierung der Konzernbesteuerung innerhalb und an den Außengrenzen der Europäischen Union, ZEW Discussion Paper No. 07-043, Mannheim.