Corporate tax harmonization in the European Union

Dankó, Zsófia (2012): Corporate tax harmonization in the European Union. Published in: Crisis Aftermath: Economic policy changes in the EU and its Member States, Conference Proceedings, Szeged, University of Szeged , Vol. ISBN 9, (2012): pp. 207-218.

Abstract

The recent financial and economic crisis of the European Union had exposed the necessity to complete monetary union with an economic union. One of the assets of a stronger economic integration is the harmonization of the tax systems (e.g. the corporate tax regimes) of the 27 Member States. Having this in mind, the European Commission proposed a common mechanism for the calculation of the corporate tax base, the consolidation of the tax bases incurred in the different Member States and the subsequent allocation of the consolidated tax base between the Member States effected (formulary apportionment) in 2011. The system envisaged by the European Commission is already introduced by the world highly integrated economies, like the United States of America and Canada on a domestic level, where the corporate tax base shall be also allocated between the states and the provinces based on the formulary apportionment method. This current article aims to present and compare the elements (factors) of the formulary apportionment method applied by the United States of America and Canada, and the elements of the allocation method proposed by the European Commission.

• Item Type: MPRA Paper
• Language: English
• Keywords: tax harmonization; corporate tax; European Union
• Subjects: H - Public Economics > H2 - Taxation, Subsidies, and Revenue > H25 - Business Taxes and Subsidies; G - Financial Economics > G0 - General > G01 - Financial Crises

References

90/436/EEC: Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises

Communication from the Commission to the Council Towards tax co-ordination in the European Union - A package to tackle harmful tax competition COM(97)495, 1997

Communication from the Commission to the Council, the European Parliament and the Economic and Social Committee: Towards an Internal Market without tax obstacles COM(2001)582, 2001

Conclusions and Recommendations of the Committee of Independent Experts on Company Taxation, 1992

Conclusions of the Heads of State or Government of the Euro Area of 11 March 2011, Annex 1. – A Pact for the Euro – Stronger Economic Policy Coordination for Competitiveness and Convergence

Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States

Council Directive 2008/118/EC of 16 December 2008 concerning the general arrangements for excise duty and repealing Directive 92/12/EEC

Council Directive 90/434/EEC of 23 July 1990 on the common system of taxation applicable to mergers, divisions, transfers of assets and exchanges of shares concerning companies of different Member States

Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States

Divergence or convergence: Saving the euro, The Economist (Online), 4 February, 2011

Erős A. (2005): Adóharmonizáció – a Lisszaboni Stratégia megvalósításának egy lehetséges módja (Tax harmonization – A possible device for executing the Lisbon strategy). Társadalom és Gazdaság, 27, 1-2, pp. 193-208.

Euro Plus Pact divides non euro zone members, www.euractiv.com, 29 March 2011

European Council 24/25 March 2011 – Conclusions, EUCO 10/1/11, Brussels 20 April 2011

First Council Directive 67/227/EEC of 11 April 1967 on the harmonisation of legislation of Member States concerning turnover taxes

Franco-German Pact and a CCCTB Proposal: International Tax Review; Apr2011, Vol. 22 Issue 3.

Haufler, A. (2004): Taxation in a Global Economy. Cambridge University Press, Cambridge.

Helminen, M. (2011): EU Tax Law – Direct Taxation, 2nd ed. IBFD, Amsterdam.

Hitiris, T. (2003): European Union Economics, 5th ed. Pearson Education, Harlow.

Hofstatter, M. – Hohenwarter-Mayr, D. (2010): The Merger Directive. In Lang, M. – Pistone, P. – Schuch, J. – Staringer, C (eds.): Introduction to European Tax Law on Direct Taxation, 2nd ed. Linde, Vienna, p. 111.

Kende T. – Szűcs T. (eds.) (2009): Bevezetés az Európai Unió politikáiba (Introduction to the Policies of the European Union). CompLex Kiadó, Budapest.

Knödel, J. (2008): Indirect Taxation within the EU – Harmonisation vs. Competition. Grin Verlag.

Kopits, G. (1992): Tax harmonization in the European community: policy issues and analysis, IMF Occasional Paper No. 94.

McLure, C. (2008): Harmonizing Corporate Income Taxes in the European Community: Rationale and Implications, Tax Policy and the Economy, 22, pp. 151-195.

Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) COM(2011) 121/4

Report of the Fiscal and Financial Committee, An unofficial translation, IBFD, 1963

Robson, P. (2002): The Economics of International Integration. Taylor & Francis e-Library.

Second Council Directive 67/228/EEC of 11 April 1967 on the harmonisation of legislation of Member States concerning turnover taxes

Terra, B. – Kajus, J. (2011): A Guide to the European VAT Directives, IBFD.

Tyc, V. (2008): Harmonization of indirect taxes in the European Union. International Journal of Law and Management, 50, 2, pp. 87-92.

Unofficial translation of the Pact for Competitiveness, 3 February 2011, www.euractiv.com

What’s in a name? Pact for the Euro, The Economist (Online), 25 March, 2011