The Commission will propose that, until full CCCTB consolidation is introduced, group entities should be able to offset profits and losses they make in different Member States. This would remove a major tax obstacle in the Single Market for businesses, by allowing them temporary cross-border loss relief so that they pay tax on their net profits in the EU.
To ensure that one Member State does not definitively carry the burden of losses incurred in another Member State, there would be a mechanism to recapture these losses once the group entity is profit-making again. The Commission plans to include this initiative as one of the stages in its revised proposal on the CCCTB.