Answer given by Mr Moscovici on behalf of the Commission
The Commission is aware that some big multinationals use sophisticated tax structures to try to minimise their tax burdens and that Member States' tax authorities can find it difficult to tackle the problem. Indeed, international tax treaties were devised at a time when intangibles, distance sales and complex supply chains were not yet playing such an important role as in today's business models (not only in the digital sector). This is why the fight against tax evasion and tax avoidance has become such a high political priority, both at EU and international level. To this end, the Commission has set an ambitious program for 2016 which includes the presentation of the re-launched Common Consolidated Corporate Tax Base (CCCTB) before the end of 2016, and the Anti-Tax Avoidance Package adopted on 28 January 2016. This package includes an Anti-Tax Avoidance Directive, a proposal for country-by-country reporting between tax authorities and also sets out a new EU strategy to protect the Single Market from external base erosion threats.
It is important to note that EU institutions and Member States have to work together with the objective of achieving a fair and efficient corporate taxation in the EU. As described in the question, Member States are currently putting effort into ensuring that companies pay their fair share of taxes. From the Commission's perspective, preferential regimes and individual tax rulings are currently subject to targeted enforcement action under state aid rules. In this context, it is not evident that the idea of requiring compensation would better fulfil the objectives mentioned, given that if companies are found to have illegally avoided their tax obligations, then they will be required to pay tax due.