The Principle of Territoriality and its Implementation In the Proposal for a Council Directive On A Common Consolidated Corporate Tax Base (CCCTB)

Abstract

The EU Commission put forward its proposal for a Directive for a Common Consolidated Corporate Tax Base with some delay after long preliminary work. That proposal provides for a uniform corporate tax base which may be relied upon in all EU Member States. Its underlying objective is to reduce the administrative burden for companies. This paper focuses on some provisions of the proposal, which are relevant for companies which are tax resident outside the EU or for commercial activities carried out there, and for EU resident companies that operate in third countries. The territoriality principle, on which the CCCTB concept is based, and its legal technical structure, are primarily discussed.