Thursday, 7 June 2012

EU Council comments on CCCTB project issued

The Council Presidency recently made public its comprise proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) as emerged from the deliberations in the Council Working Party on Tax Questions. The paper also includes interesting Presidency comments on the comprise proposal, e.g. on the introduction of a interest limitation rule (Art. 14a), on the arm´s length principle with PEs (Art. 79), and on tightening of anti-abuse rules (e.g. Art. 80 (general anti-abuse rule), Art. 82 (controlled foreign companies and permanent establishments in low tax countries), and Art. 83a (Hybrid mismatch)).
Source & more info: EU Council