5.3.4.1 Introduction

The CCCTB is a water’s edge consolidation approach (applied to a bloc group) proposed in the EU. In March 2011, the EC submitted a draft proposal on the CCCTB.1 The EC presented this proposal as a solution to eliminate major tax barriers in the internal market for companies operating in more than one Member State. The coexistence of different tax systems can lead to double taxation and creates high administrative burdens for businesses. The proposal entails a common consolidated corporate tax base at EU level. The proposal includes a set of rules that companies operating across-borders within the EU can use to calculate their taxable profits. As a result, such a company would no longer have to deal with the national tax systems of the various Member States. The proposal also includes a one-stop-shop method for tax returns and assessments. Groups within the EU would only have to deal with one tax authority when applying the CCCTB. Due to opposition from various Member States, the proposal presented in 2011 was withdrawn.

In October 2016, the EC published two draft directives. The first proposal concerns a Common Corporate Tax Base (CCTB).2The second proposal is the CCCTB.3 In these proposals, the CCTB is presented as a first step towards achieving the CCCTB. The phased approach is chosen as it is unlikely that the CCCTB proposal will be adopted in its entirety.4 In June 2021, the EC indicated that the CCCTB proposal will be replaced by BEFIT in 2023. As indicated in par. 1.5, the two proposals are based on the same idea, seem to have a similar approach and are aimed at achieving the same goals. As a result, the CCCTB is included in this research, even though it will be replaced. Below the highlights of the CCCTB and the pros and cons of the system are discussed. To conclude, its concurrence with tax treaties is described.