1.2.Developing a staged approach to implementing the CCCTB
The CCCTB is a very ambitious initiative. Discussions in the Council have shown that it will not be adopted in one piece. Difficult debate on the more complex aspects is holding back potential progress on other important elements of the proposal. Therefore, the Commission is advocating a step-by-step approach to agreeing on the different elements of the CCCTB.
Consolidation has been the most difficult aspect in Member States' negotiations on the CCCTB. Therefore, the Commission will propose that work on consolidation is postponed until after the common base has been agreed and implemented.
The primary focus should be on securing the common tax base. The Commission will review the elements in the proposed base, to reflect Member States' discussions so far and to ensure it contributes to the growth and jobs agenda in the EU. In particular, the Commission will consider whether the beneficial treatment of Research and Development expenses in the current proposal should be further developed and whether to address the corporate debt equity bias in order to strengthen the capital markets union.
The Commission will present a new legislative proposal next year, adjusting the base accordingly, introducing the mandatory element and providing for a staged approach to the CCCTB. This would include an element of cross border loss relief initially, until consolidation is re-introduced at a later stage.
