Volume 44 (2016) / Issue 6/7

Luca Cerioni, 'The Quest for a New Corporate Taxation Model and for an Effective Fight against International Tax Avoidance within the EU' (2016) 44 Intertax, Issue 6/7, pp. 463–480


The European Commission’s Action Plan for a Fair and Efficient Tax System within the EU, and the subsequent ‘Anti-Tax Avoidance Package’ (ATAP), set out a number of short-term initiatives aimed at achieving an optimal corporate tax system and at fighting international tax avoidance within the EU. Pending the desired introduction of the Common Consolidated Corporate Tax Base (CCCTB) as a long-term goal, these initiatives have been considered as capable of stabilizing Member States’ revenues and of allowing corporate taxation where profits are really generated. Since specific suggestions made in the academic literature – namely, the suggestions for a ‘destination-based corporation tax’, for a ‘corporation tax 2.0’ and for a ‘new common consolidated tax base’ – have the same objectives, this article critically discusses these suggestions and it analyses whether they can be considered as more consistent or as less consistent with the common objectives than the Commission’s initiatives. It also elaborates the hypothesis for a solution capable of both collecting the key input offered by these suggestions and being complementary to the CCCTB.

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ISSN: 0165-2826
ID: TAXI2016038