October 2016
CORPORATE TAX REFORM PACKAGE | ||
Hybrid Mismatches | ||
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The corporate reform package proposal published on 25th October, 2016 provides three new proposals to provide for a more modern and fairer tax system for business , to close loopholes between EU countries and non-EU countries and to provide new dispute resolution rules to relieve problems with double taxation for buinesses.
The Commission has proposed to re-launch the Common Consolidated Corporate Tax Base (CCCTB). The CCCTB will overhaul the way in which companies are taxed in the Single Market, to ensure a fairer, more competitive and more growth-friendly corporate tax system. The re-launched CCCTB will be implemented in two steps. It also contains important new elements to improve its anti-avoidance and growth-promoting capacities.
The Commission has also proposed an improved system to resolve double taxation disputes in the EU. Double taxation is a major obstacle for businesses, creating uncertainty, unnecessary costs and cash-flow problems. Under the proposal, current dispute resolution mechanisms will be adjusted, to better meet the needs of businesses. In particular, a wider range of cases will be covered and Member States will have clear deadlines to agree on binding solutions to cases of double taxation.
The package also includes a proposal to extend the rules against hybrid mismatches as provided for in the Anti-Tax Avoidance Directive agreed in June, to hybrid mismatches involving non-EU countries.
Press release
Questions and answers
Chapeau Communication on the Corporate Tax Reform Package
Factsheet