International Aspects of Common Base Taxation

Abstract

This paper provides a discussion and analysis of the international tax aspects with respect to the possible introduction of a Common Consolidated Corporate Tax Base (CCCTB) in the European Union. More specifically, the research question to be answered in this paper is how investments outside of the EU (outbound investment) and foreign investment in the EU (inbound investment) should be considered in the CCCTB system. In particular, this paper looks at the legal limits set by international tax law to the possible international scope of European common base taxation.