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Procedure : 2011/0058(CNS)
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Document selected : A7-0080/2012

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Debates :

PV 18/04/2012 - 16
CRE 18/04/2012 - 16

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PV 19/04/2012 - 6.6
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Wednesday, 18 April 2012 - Strasbourg OJ edition

16. Common consolidated corporate tax base (debate)
Video of the speeches

  President. – The next item is the debate on the report by Marianne Thyssen, on behalf of the Committee on Economic and Monetary Affairs, on the proposal for a Council directive on a common consolidated corporate tax base [(COM(2011)0121 – C7-0092/2011 – 2011/0058(CNS)] (A7-0080/2012).


  Marianne Thyssen, rapporteur. (NL) Mr President, Commissioner, ladies and gentlemen, tomorrow, we will have the opportunity to vote in favour of a common consolidated corporate tax base. This will mean the introduction of a new Community tax framework which will contain a complete set of rules for the calculation of individual results for every company and branch of a company, wherever they are established in the European Union.

Under this system, group profit and loss results will be consolidated and that consolidated tax base, if it is positive, will be allocated across all relevant Member States. Member States will then be able to apply their own tax rate to the portion allocated to them using a system where the entire administrative process will be managed by a single main tax authority.

With this CCCTB, we will be making it fiscally simpler and administratively cheaper for companies to develop transnationally, which will definitely open up new opportunities for SMEs. Moreover, we will be making taxation more transparent. We will be preventing overtaxation and double taxation, as well as any manipulation undertaken for the purposes of tax evasion. And, we will undoubtedly be making Europe more attractive for foreign investors.

Ladies and gentlemen, our report retains the architecture of the excellent proposal drafted by the Commission, but it shows more ambition. That fits in perfectly with the double battle we are fighting today and have been discussing all afternoon.

If we want to revive our economy and make it more competitive, we need to be prepared to do away with all barriers in the internal market, including those in the field of direct taxation. And if we want to resolve the debt crisis, we also, obviously, have to ensure that Member States are able to collect the taxes due to them. With this proposal, we will be helping to achieve both of these things.

Let no one here, therefore, invoke the crisis in order to kick everything into the long grass or take the soft line. No, if anything, the crisis should make our ambition and our sense of urgency even stronger.

Ladies and gentlemen, I would draw your attention to three points in particular: first of all, the optional nature of the system. Though the CCCTB will start out as optional, we do think that, if the system proves to be good enough for optional use, it will also be good enough to be made compulsory. Indeed, its benefits will increase with the number of users. And that is why we have proposed a road map which will gradually make the system compulsory over a period of five years for all companies, except for SMEs. For SMEs, we first want to assess the practicality of the system and develop an instrument to guide them in the use of the system.

Secondly, we need to consider the scope of harmonisation. This proposal does not address rates, but only the taxable base, the basis on which tax is levied. As regards tariffs, Member States will retain their full sovereignty. However, we do explicitly ask that this matter be included in the revision clause, in a way that will subsequently enable us to examine whether or not, and to what extent, any continuing tax competition between Member States is beneficial or harmful for the Europe that we want to develop together – one that seeks to establish a social market economy.

Thirdly and finally, Mr President, we think that we have to make headway. If the Council fails to reach consensus with the 27 Member States – and it is a pity that the Council is again not being represented here – we will ask the Commission to immediately start the procedure to implement the proposal with close cooperation.


  Algirdas Šemeta, Member of the Commission. – Mr President, honourable Members, I wish to thank you and, in particular, Marianne Thyssen, for her work on this report. I welcome the positive views from the Committee on Economic and Monetary Affairs and the Committee on the Internal Market and Consumer Protection on our proposal for a CCCTB. It was one of our flagship legislative initiatives for 2011.

A system of common rules for calculating the tax base across the EU is expected to significantly improve the business environment in the single market. It will contribute to the efforts for bringing the Union back to growth and prosperity.

I would like to address five main points in the report.

First, the Commission proposed the CCCTB as an optional system. I believe that an obligatory scheme would introduce a significant burden by obliging businesses with purely domestic activities to bear the cost of switching into another tax system.

Second, I am convinced that an apportionment mechanism based on a formula of three equally weighted factors – sales, assets and labour – is the most appropriate solution. It creates a fair balance between the states of origin and destination. I would also say that there is no economic evidence which suggests that a weight of 10% for the sales factor is a better option.

Third, the Commission would not be opposed to the idea of setting up a forum with tasks similar to those of the Joint Transfer Pricing Forum, provided that the outcome of such an effort does not create a risk of incompatibility with the Treaty. In this regard, the reference to a ‘dispute settlement body’ with possible binding decisions could be found to conflict with the Treaty.

Fourth, the Commission has consistently made it clear that the CCCTB proposal is only meant to deal with the rules for computing the corporate tax base and should not touch upon minimum tax rates. Increasing the exemption threshold to 70% in certain anti-abuse clauses would inevitably and unnecessarily raise arguments at a political level about a minimum corporate tax rate in the EU.

I should finally mention that the review clause as suggested by the Commission (five years after the directive entered into force) can offer opportunities for improving the CCCTB scheme. Its scope is very broad. By listing the issues to be addressed, we would lose the flexibility we need to analyse the points raised in your report.

These were my main points of concern, but in general, I welcome the report very much and I am looking forward to a very positive vote tomorrow.


  Olle Schmidt , rapporteur for the opinion of the Committee on the Internal Market and Consumer Protection.(SV) Mr President, a common consolidated corporate tax base is an important first step towards improving the competitiveness of European companies and a more efficient single market. It will provide more jobs, reduce companies’ costs and eradicate unnecessary red tape.

In the opinion of the Committee on the Internal Market and Consumer Protection, we proposed amendments to the Commission’s proposal. Ms Thyssen has included several of these in her compromises, which is something we welcome.

These include the establishment of a joint forum for dispute settlement, which is something that Commissioner Šemeta also mentioned.

In the committee’s opinion, we also stated that the introduction of a common consolidated corporate tax base should be voluntary. It is beneficial to have competing tax systems and institutional competition.

The system should not be mandatory until we have practical experience of how it will work.

I believe that more companies than just those referred to as European companies will be willing to participate if the system is voluntary. It is therefore unfortunate that the compromise already involves the gradual introduction of a mandatory system.

This will make it harder to get more Member States to participate. Better a carrot than a stick.


  Jean-Paul Gauzès, on behalf of the PPE Group. (FR) Mr President, Commissioner, the draft directive aims to implement within the European Union a common consolidated corporate tax base, known as the CCCTB. This has been under discussion since 2004. Today, Parliament, having been asked for its opinion and by way of Marianne Thyssen’s report, wishes – or in any case, the Group of the European People’s Party (Christian Democrats) wishes – to send a strong message encouraging the Commission to continue its work in this area.

The implementation of a CCCTB in the European Union offers many benefits, both for economic operators – by removing tax obstacles from the internal market – and for Member States – by enabling more transparent and therefore healthier tax competition between Member States.

The report, voted through by the Committee on Economic and Monetary Affairs and presented by Ms Thyssen, is excellent. After lengthy negotiations and skilful identification of how best to address a very delicate issue, that is to say, the voluntary or optional nature of the system, she is proposing – and has reached agreement on – a phased transition, with the regime becoming immediately compulsory for European companies and cooperatives, to be extended to all companies with the exception of SMEs after five years, following review by the Commission.

Commissioner, I believe the Commission should be more demanding in this area. I know the proposal is not strongly supported by several Member States, either due to a principled opposition, such as that of the United Kingdom, to complete tax harmonisation, or due to fears that would be provoked by implementation of this system. This is the stance of Poland, the Netherlands and Luxembourg, for example. It must be disregarded. It is crucial for the European Union that this consolidated base, which does not involve a harmonisation of taxes, is implemented. That is the view taken of your proposal by the PPE Group.


  Liem Hoang Ngoc, on behalf of the S&D Group. (FR) Mr President, I want to thank the rapporteur for the political will she has displayed in this report.

We all know that some Member States manipulate their corporate tax base more or less secretly to reduce their real level of taxation and practise tax dumping. That is why we, as socialists and federalists, have always supported the idea of moving towards tax harmonisation in the European Union. Unfortunately, by proposing a consolidated base that was merely optional, the European Commission did not seek to take a first step towards harmonising corporate tax, but simply to create a tax optimisation instrument. This was not acceptable to our political grouping, since the Europe we believe in is not a self-service Europe serving only corporate interests. It is, above all, a political and social Europe built for all, involving everyone.

As shadow rapporteur for the Group of the Progressive Alliance of Socialists and Democrats in the European Parliament, I have fought for months to change the logic of the Commission’s text radically, namely, to move from a voluntary to a compulsory system and introduce a minimum level of taxation. Negotiations were not easy but we succeeded in reaching agreement because, beyond our political differences – which are significant – all of us around the table shared an ambitious vision of Europe.

Despite her initial reluctance, the rapporteur ultimately accepted the principle of a compulsory common consolidated corporate tax base for all large companies in the EU. Unfortunately, we did not manage to establish a minimum rate but the report clearly identifies the problems posed by too large a spread in rates and calls for the issue of rates to be re-examined when reviewing the application of this text. We will monitor this closely, because for us, it is an indispensable second phase.

Therefore, ladies and gentlemen, I call on you to give overwhelming support to Ms Thyssen’s report. In doing so, we will send a strong message to the Council and, above all, to citizens, who are the first to suffer from the evils of tax competition.


  Carl Haglund, on behalf of the ALDE Group. – Mr President, I would like to thank the rapporteur for a good report. Our group is also very supportive of the lines taken in the committee; this is a possibility to actually enhance the internal market and to ease the administrative burdens of companies which really want to push for cross-border activities in their field.

In general, I think that the development in committee has taken this report in the right direction. We can, of course, debate whether it is a good decision or not to make this scheme compulsory for companies, but if we want to actually succeed, I am convinced that the voluntary scheme is not necessarily going to activate as many companies as one would hope.

The discussion about whether we should harmonise corporate taxation or not does not belong here, but the fact of the matter is that we already have the minimum and maximum type of taxation solutions, for instance, in the field of value-added tax, and we should definitely consider this. But that is another report.

Last but not least, I am happy that we were able to change the way we are weighing the different ways of distributing, because having too much weight on sales is not going to give us a good result for countries that are competing within the export sector.


  Philippe Lamberts, on behalf of the Verts/ALE Group.(FR) Mr President, I think that from a political point of view, this is an extremely ambitious report. I believe, Ms Thyssen, that you have gone as far as you can if you wish to gain a large majority in this Parliament.

If we truly want to put an end to tax optimisation, then this is the first step in terms of corporate tax. Clearly, it is unthinkable for us to establish a voluntary 28th corporate tax system alongside the 27 Member State systems, as evidently who will use it if it is optional, other than companies for whom it would constitute a lower effective tax rate than if they were to use their national system? Indeed, I think that it is essential to make this system obligatory for large companies and I thank the rapporteur for having included that in the report.

As for the Council, which once again on the subject of tax is conspicuous by its absence, I would simply like to say one thing: by playing the game of tax competition with each other, we will all end up losers and all our public purses will suffer. It is not a zero-sum game, but a negative-sum game. This is why I hope that the message to be sent by this Parliament tomorrow will be heard by the Council.


  Ivo Strejček, on behalf of the ECR Group. (CS) Mr President, when listening to the debate, I made three observations, so to speak, which will not surprise members of the Committee on Economic and Monetary Affairs, at least, as they are familiar with my observations.

First, European conservatives firmly believe that tax competition is a good and healthy thing, and any attempt to harmonise tax rates is unacceptable to us. Secondly, we consider this report a breakthrough in terms of a direct taxation system, since, from a purely accounting perspective, if there are two variables in a formula – the rate and the base – and you change one of the variables, then you change the entire calculation. This is the way to the breakthrough. Thirdly, we insist that this system must also be strictly voluntary in the long term, and it should be up to individual businesses whether or not to join the system. I have many other observations, but these are the main ones.


  Godfrey Bloom, on behalf of the EFD Group. – Mr President, harmonised taxation is simply a ploy to enable bureaucrats to steal even more money from the wealth-creating sector. Like vampires, they prey upon ordinary folk, sucking the lifeblood out of the economy – and for what? Tax-free salaries, non-contributive pension schemes, winter sunshine trips to Durban and Cancún, suicidal remote energy policies and constant rescue packages for failed banks.

Without tax competition, Europe would be bled white in pursuit of a maniacal political crusade. High tax would banish manufacturing to the Far East, the Indian subcontinent and North America. The Baltic States, Ireland and fellow entrepreneurial ex-Warsaw Pact countries would slip back into the abyss. Athens and Madrid would become Dublin and Warsaw, but I suspect that before that time, ordinary folk will have cried enough and the parasites will have to head for the hills, as well they may. For certain the Irish, I suspect, will have their own way of dealing with them when they eventually awake from their slumber.


  Theodor Dumitru Stolojan (PPE).(RO) Mr President, I wish to say a special word of thanks to Ms Thyssen for her efforts in producing this excellent report. Even though the development of economic integration requires a system for creating a common consolidated corporate tax base for companies operating in more than one Member State, even though the draft directive makes it optional for companies to join this system, and even though every Member State is entitled to apply the tax rate it wants to the part of the consolidated tax base which is apportioned, we still have a situation where some national parliaments have lodged objections, including the parliament in my country, giving the violation of the principle of subsidiarity as the reason. Some governments are also against this draft directive.

I call on the Commission to give this matter its full attention, in particular, the position of the national parliaments. I believe that it is useful to meet with these national parliaments which have cited the violation of the principle of subsidiarity, and we in the Committee on Economic and Monetary Affairs are ready to take part in this dialogue.


  Antolín Sánchez Presedo (S&D).(ES) Mr President, it has been said that the fiscal sector remains unfinished business in European integration. We need to make progress on that unfinished business in order to consolidate our successes, face the current challenges and achieve credible economic governance. Furthermore, if this is to be done with full democratic legitimacy, then Parliament should not play a merely consultative role.

The creation of a common consolidated corporate tax base (CCCTB) is a long awaited step and a vital initiative for combating harmful tax competition, eliminating tax arbitrage and fairly attributing the profits and losses of companies of the same group located in different Member States. Its introduction could contribute to transparency, which will facilitate comparison of fiscal effort, and simplification, which will reduce administrative and management costs caused by disparate legislation; it will also establish a level playing field so that resources can be used more equally and fairly. All of this will help our objective of promoting growth and sustainable employment.

The Commission’s proposal provided greater fiscal consistency in an area in which there are already bilateral initiatives, but it offered an optional system and à la carte consolidation for national companies.

The compromise reached in the Committee on Economic and Monetary Affairs is satisfactory because it allows for the gradual implementation of the measure and, at the same time, it considers the possibility of a review clause that includes the analysis of minimum rates. I therefore wholeheartedly support it.

(The speaker agreed to take a blue-card question under Rule 149(8))


  William (The Earl of) Dartmouth (EFD), Blue-card question. – Surely experience has shown that low taxes mean more jobs and more growth. Why, therefore – as you stated – is fiscal competition harmful?


  Antolín Sánchez Presedo (S&D), Blue-card answer.(ES) Mr President, I do not share that experience. I do not believe that the Member States – Europe being a clear model offering the best results – can exactly be counted among those countries with lower fiscal participation.

However, in any case, it is clear that harmful tax competition does exist and that initiatives such as this can help reduce it and eliminate it, and in the area of taxation we need to intensify cooperation and solidarity within the EU.


  Derk Jan Eppink (ECR). (NL) Mr President, the differences between Member States in terms of corporation tax are large, whether we are talking about rates or revenues. For that reason, the Commission has opted for harmonisation by the back door.

A uniform corporate tax base has its advantages. Companies will pay tax more cheaply and more easily. Who ultimately receives the tax revenues is none of their concern. It is the concern of Member States and that is where the shoe pinches. When Member States collect corporation tax from companies operating in several Member States, they have to divide the revenue between them. The allocation key which the Commission has devised for this purpose adversely affects competitive and exporting countries. They are fiscally punished and lose revenue from corporation tax.

Ms Thyssen’s report already explicitly states the solution that will soon be submitted to these countries, namely minimum corporation tax rates and, yet, we have not carried out any thorough research into the fiscal effects of the allocation key proposed by the Commission.

I therefore say: I am not going along with this and I believe that a large part of the Council will agree with me.


  Diogo Feio (PPE).(PT) Mr President, taxation issues are always controversial when discussed at European level; it is no accident that the Treaty of Lisbon provides for a unanimity rule in relation to the majority thereof. It is also no accident that most EU-level provisions in this area have related to indirect taxation. However, as this relates to taxation issues, we are debating the workings of the internal market, the workings of the concept of sovereignty, and own resources in the EU budget.

Parliament has adopted a very clear stance on these issues, always with a view to the need for balance between these decisions and maintaining the tax burden on individuals and companies.

Parliament has already mentioned the need for EU-level taxes several times. Harmonisation of accounting rules – first and foremost, for corporation tax – and also here through Ms Thyssen’s extraordinary report, which tackled the issues of voluntary tax neutrality, of simplification for businesses and less bureaucracy, of anti-abuse rules, and of less evasion. The ball is now in the Council’s court. We hope that this crisis will also be an opportunity to defend the internal market and to defend companies.


  George Sabin Cutaş (S&D).(RO) Mr President, the report which we are going to vote on tomorrow sends a powerful message to the governments of the Member States which support the introduction of a company taxation system at European level. This request has been submitted by Parliament on several occasions as it marks a step towards completing the European internal market and achieving Member States’ economic integration.

We must not forget that many companies are doing business nowadays in more than one EU country. As a common set of rules in this area, the common consolidated corporate tax base will cut companies’ administrative costs significantly and increase transparency, which is bound to make the EU, in practical terms, a more attractive place for investors. The Commission estimates that the costs involved in legislation compliance will fall by EUR 700 million a year, along with a drop in the number of tax evasion cases. Based on this, I support this proposal and I think that it is necessary in the future to apply the system to small and medium-sized enterprises and introduce a minimum European taxation level. I also hope that Parliament’s proposal will be given full consideration by the Council of Ministers.


  Ashley Fox (ECR). – Mr President, at this time of crisis, Parliament should bring forward proposals that assist growth and job creation, and instead we have a proposal to harmonise the corporate tax base. This is a very bad idea. Tax competition is good. It keeps governments honest. It stops them taking too much money from the productive sector of our economy, and we in the EU should aim to keep corporate taxes as low as possible. This is a backdoor step to try and ratchet corporate taxes up. This proposal also treads on the powers of the nation states. We should remember in this place that it is for the nation states to decide what taxes to levy on their citizens. Long may that remain so.


  Krišjānis Kariņš (PPE).(LV) Mr President, Commissioner, in my view, one of the most important tasks we face in Europe today is to secure economic growth. I know of at least one European politician who, in fact, hopes to destroy economic growth completely with his initiatives, by proposing a 75% tax rate. This legislative initiative takes the opposite direction in my opinion. It would directly encourage economic growth, not hinder it.

What is the situation? Currently in Europe, any business operating in several Member States must deal with a different tax system in each of those states. That means time, that means money, that means costs. With this legislative initiative, all this would be simplified, and businesses would have the possibility of dealing with the tax system of a single country. Where tax would be payable, this Member State would also apportion this amount among other Member States where the business operates, according to a formula. So, ladies and gentlemen, we do not need to move in the direction that would hinder the development of entrepreneurship and economic growth. We have to take a direction and do everything that we can that will encourage economic growth in the European Union. This legislative initiative is exactly of the kind that would help us attain that objective. Thank you for your attention.


  Edvard Kožušník (ECR). (CS) Mr President, Commissioner, I would like to stress that the area of taxation falls exclusively within the competence of the Member States. I am very concerned about the attempts to apply a consolidated tax base.

On the one hand, the submitted proposal argues that a consolidated income tax base will reduce the administrative burden on businesses. Unfortunately, it overlooks the fact that the common tax base would necessarily be broader than the existing one in some countries. The tax burden would thus be indirectly increased in these countries, without increasing nominal tax rates. The submitted proposal is a stalking horse, through which the Commission is trying to breach the tax sovereignty of Member States. It introduces tax rate harmonisation by stealth.

All of this at a time when Europe is haunted by the spectre of stagflation. Instead of trying to encourage competition between the individual states of the Union, we are trying to stifle competition through tax harmonisation by stealth.


  Zuzana Roithová (PPE). (CS) Mr President, as the shadow rapporteur for the Group of the European People’s Party (Christian Democrats) in the Committee on the Internal Market and Consumer Protection, I promoted an arrangement that was intended to guarantee the fiscal neutrality of the directive. In a time of crisis, it is unacceptable that Belgium, for example, should have higher payments to the state budget at the expense of others, for example, the Czech Republic. The formulation of the Committee on Economic and Monetary Affairs is not a practical solution but a political declaration. However, I hope the Council will respect it.

I welcome the fact that the Committee on Economic and Monetary Affairs has accepted our proposals concerning the fight against tax evasion, stricter rules for tax havens, simplification of the administration of cross-border businesses, flexibility in out-of-court dispute resolution and retention of the voluntary nature of this EU regime for small and medium-sized enterprises. I also support the introduction of a unified tax formula, and I would like to express my thanks for it. I am delighted that the proposals for introducing a minimum tax rate did not get through, and that, quite the contrary, the tax sovereignty of states, including tax rates, was unanimously confirmed, thus confirming the principle of tax competition.

I do not welcome the fact that the individual requirements as to what a future review of this directive should include are so general. I do, however, strongly support the common consolidated corporate tax base. This version of the directive will undoubtedly be of great benefit to businesses. I hope Czech entrepreneurs are able to choose this intelligible and stable European system. We can expect the Council to veto the proposal, however, so that it continues only within the framework of enhanced cooperation, and is applied in just a few countries. I hope that the European system will serve as an example for other countries, including the Czech Republic, of what can be sensibly included in the tax base and how it can be included, so that businesses are not discouraged from paying tax in the Czech Republic.


  Gay Mitchell (PPE). – Mr President, I would like to thank my colleague, Marianne Thyssen, for her work on this report, although I have concerns about the report itself.

While my country, Ireland, has constructively engaged in the CCCTB process to ensure that all the arguments are looked at closely, I would like to stress two issues of EU law. One: the Treaty requires unanimity in matters of taxation policy, and two: the principle of subsidiarity allows Member States to keep taxation within national legislation. My main concern is that this is transgressing national competence.

While the report does not specifically call for the harmonisation of tax rates (albeit Amendment 10 comes close), the introduction of common rules across all Member States for the calculation of the tax base of companies is nonetheless, in my view, a matter for the Member States.

About ten of the amendments go too far. Furthermore, we are block-voting, so few choices are available. I also want to point out that I do not believe that it is necessary for us to seek another report on the merits of taxation as a form of competition. I believe former Commissioner Monti has dealt with that very well.

Lastly, Rule 38a(1) of Parliament’s Rules of Procedure on the examination of respect for the principle of subsidiarity states that ‘during the examination of a proposal for a legislative act, Parliament shall pay particular attention to respect for the principles of subsidiarity and proportionality’. I do not believe we have done so on this occasion. These are my reservations.




Catch-the-eye procedure


  Nadezhda Neynsky (PPE). (BG) Mr President, I oppose the proposal to make the consolidated corporate tax base compulsory for all companies. This would violate the principle of subsidiarity, triggering an adverse impact for some national economies, including Bulgaria, which depends on its competitive advantage to attract investors based on simplified tax rules and low tax rates.

Of course, the idea for a consolidated tax base as a measure to complete the single market, which will facilitate the development of international business, reduce the administrative burden and save the time and money needed to learn 27 different tax systems, is understandable. I believe, however, that this scheme must remain voluntary because it leaves the decision of whether to join it or not in the hands of corporate taxpayers.

The best way for us to judge whether the system is successful beyond the theoretical considerations I listed would be if the voluntary principle is embraced by business. The compulsory nature of this regulation risks killing off competition.


  Petri Sarvamaa (PPE). – Mr President, I will say two things, one very realistic and one extremely idealistic. The realistic thing is that we have to praise Marianne Thyssen for doing something finally to take us from talk to action. I think every cloud has a silver lining and here I see such a case, where economic crises have led us from talk to action. This CCCTB is a chance to stimulate businesses and at least do something about Europe’s competitiveness collectively. But then, idealistically speaking – and I know we are maybe 100 years from this – I would like to see this as the first step towards harmonising much more. This act does not have anything to do with harmonising the tax rates but perhaps one day it will be seen as the first step towards that. It is not realistic in today’s Europe and in today’s situation, and to many ears I know it sounds naïve, but idealism is basically what we are here for.


  Monika Flašíková Beňová (S&D). (SK) Mr President, the proposal for a uniform set of rules for determining the tax base for businesses certainly contains a number of positive aspects. The proposed rules will increase the competitiveness of the European Union and stimulate economic growth and job creation. The EU would also become more attractive for other foreign investors. I would also like to underline that an important or positive aspect must also be the resolution of the issue of evasion using tax havens. During the current economic crisis, with the significant impact that it is having, particularly on the most vulnerable groups in society, we cannot allow European multinational corporations to move their profits to countries with minimal tax burdens; what is more, the loss of such financial resources also significantly weakens our national budgets. Strict taxation will greatly help the weakened economies of the Member States, and this can have a very positive effect on their social policy. Tax harmonisation, however, will be effective only if the CCCTB enters into force in all EU Member States.


  Andrew Henry William Brons (NI). – Mr President, if pushing for greater political and economic integration and harmonisation were a criminal offence, the EU would be pulled in as the first and only suspect. Its fingerprints would be all over the scene of the crime. However, more charitably, we can see it as a repeated nervous tic or obsessive-compulsive disorder.

A demand for a common consolidated tax base can be seen simply as a different example of the same tic, another obsessive desire for greater political integration. This morning, it was integration by coordination of the social security system; in the early evening, it is integration by a common corporate tax base; later this evening, the target for integration will be taxation on electricity and energy products.

Do these people dream about greater political and economic integration? When they are invited to parties –if they are – and see an attractive member of the opposite sex – or the same sex, if you prefer – do they try to sweep them off their feet with coded references to political and economic integration, possibly coupled with an unpleasant leer? I only ask out of curiosity.


End of the catch-the-eye procedure


  Algirdas Šemeta, Member of the Commission. – Mr President, honourable Members, I would like to thank you for the views you expressed during this debate. Your strong support and constructive approach in this area is an important signal for the Member States.

As you may know, the technical work in the Council progresses. Discussions are now focused on how to calculate the tax base. The Presidency hopes to have a progress report on the CCCTB for the May ECOFIN. I believe that your approach points in the right direction for the future of corporate taxation in the Union. We need to sustain the political momentum towards a competitive and robust pan-European tax regime for the benefit of our companies and in order to attract foreign investments in the EU through a simple and efficient tax system covering the entire single market.

I take note of your call in the report – and repeated by many of you today – to make the CCCTB compulsory five years from its adoption. As I have already mentioned, the Commission is well aware of the burden that this would involve for companies that do not wish to operate cross-border. The review clause would nonetheless help us to assess the system as proposed within five years. This review may well cover the success of optionality.

I also take note of the request of Mr Stolojan to meet with national parliaments that have expressed doubts in respect of the principle of subsidiarity. I can reassure you that every visit I pay to a Member State includes a meeting with the national parliament wherever possible. Romania will not be an exception.

The rapporteur and some Members have raised the issue of enhanced cooperation. The initiative to launch an enhanced cooperation lies exclusively in the hands of the Member States. I therefore do not find it appropriate to speculate on this issue now. The Commission will therefore express its views on this matter when it is required to, according to the Treaties.

Again, I wish to thank you, honourable Members of the European Parliament, for your broad support in moving forward with this initiative. I am convinced that this is the only comprehensive solution for tackling cross- border tax obstacles in the area of corporate taxation. I personally feel reassured and willing to pick up on the strong encouragement to progress in this area, for which I thank you.


  Marianne Thyssen, rapporteur. (NL) Mr President, I would, of course, like to thank all of the speakers for their comments. However, ladies and gentlemen, I would just like to make a few additional remarks.

Major reforms are often carried out in periods of crisis and I think that we now need to seize on the current crisis, both the economic one and the crisis of public finances, in order to push ahead with the work on this dossier.

This is a dossier that we could conclude tomorrow in Parliament, as far as our part of the work is concerned, and that is indeed what we have repeatedly asked for in the past. The European Commission has worked on it for more than ten years. And let us not forget that this issue has been raised in practically every conclusion of the recent European summits and that the European Council and euro area summits have repeatedly declared themselves in favour of the CCCTB. Let us therefore remain hopeful.

Mr President, it is a fact that, with this, we are completing a part of the internal market. I cannot follow the logic of those who claim, all of a sudden, that the internal market no longer stands for growth and jobs. What we are doing here is really dismantling an obstacle in the internal market and I believe that growth and job creation are worthwhile ambitions. This is a good reason why we should continue to pursue them.

Finally, ladies and gentlemen, I was very happy to put my name to this report. I firmly believe that all of the choices we have made in this report are right and that is the case because we worked constructively together and because we listened very carefully to each other across the group lines. It is true that there are differences in emphasis. Here and there, we differ in basic assumptions, but we have shown what we are able to achieve together.

I hope that we will vote with as much unity tomorrow and that, in so doing, we will be able to whet the Council’s ambition a little. Because, again, if the Council is consistent with itself, and if the ministers of the Ecofin are consistent with their political leaders, then they will have to respond positively to this. If not all of the 27 are able to do so – which I still hope will be the case – then fewer than that, but I do hope that we will have all 27 on our side.


  President. – The debate is closed.

The vote will take place on Thursday at 12.00.

Written statements (Rule 149)


  Liam Aylward (ALDE), in writing.(GA) Taxation is an issue of subsidiarity and the Commission and Parliament must put an end to the incessant efforts to indirectly introduce European competence to taxation. The attention given to France and Germany’s request to the President of the Council to bring an end to talks on the CCCTB before the end of 2012 should not be given more attention than the major concerns of those Member States who are worried about the CCCTB initiative. The Franco-German CCCTB initiative should not be used to undermine Member States’ individual competence, under the guise of efforts to tackle the economic crisis. The CCCTB would not improve the functioning of the single market in any way, and small open economies such as Ireland’s could even be damaged as a result. A change in the rate of corporation tax would interfere with a strong aspect of the Irish economy that is crucial to the Ireland’s recovery and growth potential. According to a study recently undertaken by the European Centre for Economic Studies in relation to the implementation of the CCCTB in Europe, it would be impractical, impossible to implement and politically undesirable.


  Jiří Havel (S&D), in writing. (CS) An effective tax system is an important component of a functioning single market, which is a key pillar of EU competitiveness. The debate on a common consolidated corporate tax base (CCCTB) is therefore a step in the right direction, particularly in view of the current economic problems in the EU. I therefore welcome the Commission’s objective of unifying the CCCTB in the EU, which falls within the process of rethinking tax systems and shifting to more growth-friendly and green taxation, thus supporting the aims of the Europe 2020 strategy. I would like to point out that the tax revenues in question would be allocated by the individual Member States on the basis of a clearly defined mechanism – working from the parameters of employment, assets and revenues – that has been established sensitively on the basis of a political consensus that has taken more than 10 years to negotiate. For this reason, I hope that the planned assessment of the impact of the CCCTB five years after it enters into effect will be positive, and that it will also serve as an example of good practice for countries outside the EU. Overall, it can be said that the report submitted by Ms Thyssen presents a detailed analysis of this issue, makes reference to the relevant legislation, and also contains adequate recommendations in the area of the CCCTB, and I therefore recommend that the report be approved in its draft form.


  Jim Higgins (PPE), in writing. – I intend to vote against this report. The governments of the Netherlands, Bulgaria, Ireland, UK, Malta, Sweden, Poland, Romania and Slovakia all raised concerns regarding the Commission CCCTB proposal. Unfortunately, the majority of 18 Member States was not reached in order to require the Commission to re-examine their proposal. The argument in favour of this report is that the level of the tax rate will remain a decision for national parliaments. The objective of the report is to enhance the system of taxation of companies, not to harmonise tax rates. It is respectfully submitted that harmonisation of the tax base and the tax base rules is a form of harmonisation. The report explicitly underlines that CCCTB only concerns the tax base, not corporate tax rates. However, it does not exclude that, in the future, further steps may be taken towards tax rate harmonisation. I strongly oppose Amendment 10 which outlines that, although the harmonisation of tax rates is not at issue now, we must not entirely exclude the possibility for the future. This only serves to further aggravate subsidiary concerns already espoused by Member States.


  Ian Hudghton (Verts/ALE), in writing. – The Commission have assured us that it is not their intention to harmonise rates of corporate tax across Europe. Nevertheless, this proposal represents the EU encroaching on an area which properly lies within the competence of individual Member States. This raises questions not just of subsidiarity but, more fundamentally, of national sovereignty as the Dáil Éireann and others have noted. These problems are compounded by calls in this House for harmonised tax rates in the future. Such calls only serve to turn our citizens against the EU. The ability to set tax rates must remain one of the fiscal tools available to each independent Member State.


  Iliana Ivanova (PPE), in writing. (BG) The EU must take decisive measures to improve its competitiveness on the international stage. The proposal we are discussing today aims to create a mechanism for a common consolidated tax base for corporate taxation. However, this directive will not enable the EU to become more competitive: quite the opposite – it will deprive the European Union of the competitive advantages provided by having a variety of tax rules and rates. Some countries will benefit and others will lose out from the introduction of this common base, but one thing is certain: the end result will be to make the EU less competitive as a whole and cause an outflow of foreign investments to third countries with more favourable tax conditions.

Europe needs tax competition if it wants to attract foreign investors. The introduction of a common consolidated tax base throughout the EU will deprive individual Member States of their important competitive advantages and, in the long term, will lead to a mechanical alignment of tax rates as a result of the decrease in revenues in some of them. The EU must approach this carefully and focus its efforts on decreasing the administrative burden and improving the business environment. Unlocking the full potential of the single market is the key to economic growth and creating new jobs.


  Danuta Jazłowiecka (PPE), in writing.(PL) No one is in any doubt how important it is in a crisis to use measures which help improve economic growth and create new jobs in Europe. The idea to introduce common European rules for calculating the tax base for companies operating in the European Union is one which would undoubtedly help to improve the competitiveness of the European market and to reduce the administrative burdens and costs associated with having to comply with different national taxation regimes.

Unfortunately, the draft directive on a common consolidated corporate tax base, alongside good and legitimate measures, also introduces provisions to which, particularly during a crisis, we should not agree. One such idea is allowing for consolidation of profit and losses by groups of companies, which will cause a fall in tax revenues in many Member States and will divide Europe into countries which have ‘won’ and ‘lost’. This solution represents too great an interference in the tax systems of the Member States, and the possibility of action to compensate for losses by raising tax rates poses the threat of tax competition in the internal market. Instead of creating legislation which is inconsistent with the principle of solidarity and which favours certain Member States, we should rather encourage the Member States to establish a common tax base as soon as possible, as some of them have committed to do under the Euro Plus Pact. This is a method which is neutral in terms of revenues and which ensures consistency between national tax systems while also respecting national taxation strategies.


  Vladimír Maňka (S&D), in writing. (SK) The aim of the proposal to create a common system for calculating the tax base for companies active in the EU is to significantly reduce the administrative burden, the costs of complying with legal regulations and the legal uncertainty faced by EU firms at present.

When determining their taxable income, enterprises must comply with 27 different national systems. The proposed common consolidated corporate tax base means that enterprises would be able to take advantage of the ‘one-stop shop’ system when filing their tax returns and could consolidate all of their profits and losses incurred throughout the EU.

Member States would retain their full powers when determining corporate income tax rates. This system will save businesses across the EU hundreds of millions of euro every year in the cost of complying with legislation. In addition, enterprises with ambitions to expand beyond borders will benefit through savings of up to EUR 1 billion. The system will help create new jobs, help in the fight against tax evasion, will be beneficial for the EU’s global competitiveness, and will increase the attractiveness of the EU in the market for foreign investors.


  Sławomir Witold Nitras (PPE), in writing.(PL) The plan to establish a single corporate tax base throughout the European Union is one which is both ambitious and necessary. It is ambitious because legislation on this tax differs significantly between Member States not only in terms of how it is structured, but also in the level of detail and the economic priorities of individual Member States as reflected in the tax. It is necessary because it will allow companies which do business across borders to make significant savings and will also make their work easier.

However, introducing consolidation of revenues is not such a good idea, at least not for all the Member States. The formula for apportioning the consolidated tax base means the emergence of a group of ‘winner and loser’ Member States, or those whose budgetary incomes will rise and those whose incomes will fall after this measure has been introduced. Therefore, it will be extremely difficult to work out a compromise which would satisfy all the parties, and if a compromise were to be reached, the resultant situation might, in any case, have an adverse effect on relations between Member States.

Therefore, I think that establishing a common tax base should be a priority, but the idea of consolidation should be rejected. This would be a much better solution because it would accelerate the process of building the single market without unnecessary delays, particularly in view of the fact that the Euro Plus Pact shows there is a broad consensus to begin such a plan.

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