The CCCTB initiative as a possible solution to the conflict between the internal market and national tax autonomy

Abstract

In 2016, the European Commission re-launched the project for a common consolidated corporate tax base with a two-step approach of two interconnected proposals of Common Corporate Tax Base (CCTB) and Common Consolidated Corporate Tax Base (CCCTB). The proposals faced fierce opposition from several Member States, even if few oppose combatting tax avoidance and eliminating tax obstacles of cross-border trade in principle. This article examines the CCCTB proposal as a possible solution to the conflict between the internal market and national tax autonomy. When focusing strictly on the said proposals in their current form, analysis of their capabilities to solve the conflict seem dim. On the other hand, if the CC(C)TB is seen as a system of formula apportionment and as an evolving framework, which can be enacted in parts of the internal market through for example enhanced cooperation, the outcast looks more positive.