An outline of the CCCTB (Common Consolidated Corporate Tax ...

company of an EU subgroup chosen by the group or, in the absence of EU
subgroups, on any other company chosen by the group.
This status of principal taxpayer would be conferred for as long as the group
remained subject to the CCCTB, and the appointed company would be under
obligation to ensure compliance with the relevant administrative requirements.
The principal tax authority, for its part, would be the revenue administration for the
place where the principal taxpayer was resident for tax purposes. If the principal
taxpayer were not resident in the EU, the principal tax authority would be the tax
administration for the location of a permanent establishment.
The drawbacks of this system could be the curtailment of the Member States’ fiscal
sovereignty and the risk of a lack of impartiality on the part of the competent
administration, the principal taxpayer being, by definition, resident in the territory of
the sole competent authority. Moreover, some experts fear the emergence of a
phenomenon they describe as ‘principal-tax-authority shopping’, whereby the main
taxpayer would be chosen on the basis of the characteristics of the tax authority
with which it would necessarily be associated.
Opting for the CCCTB
Groups would have to notify the competent tax authority of their intention to opt into
the CCCTB regime at least three months before the start of the relevant tax year.
On the basis of the ‘all-in or all-out’ principle, the option would apply to all
companies included within the consolidation perimeter. .
Notice of the intention to opt should be deemed to have been accepted six months
after receipt unless explicitly rejected by the competent tax authority.
Company and group tax returns and tax-base procedure
Taxation would be based on a system of self-assessment. Each taxpayer in the
CCCTB group would therefore be required to complete its own tax return. In cases
where the group was consolidated, however, the principal taxpayer would be
responsible for submitting a single consolidated tax return on behalf of all group
members.
This tax return would have to be submitted no later than nine months after the end
of the tax year to which it related.
Inspections and investigations in the company’s premises would be decided jointly
by the principal tax authority and the other competent tax authorities. The findings
of these inspections and investigations would be collated by the principal tax
authority, which, by agreement with the other authorities, would issue an amended
assessment. The notification of this assessment would be made by each of the
concerned tax authorities, as well as the notification of the enforceable notice of
assessment authorising recovery of the said amount.
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