“Common Consolidated Corporate Tax Base

Ireland's Position

• Ireland supports the Commissions efforts in transforming the European Union into the most competitive economic zone in the world but we do not believe that the introduction of a Common Consolidated Corporate Tax Base could advance the Lisbon Agenda nor that it could improve the competitiveness of the European Union.
• Our position on the CCCTB is well known. We do not favour it for reasons of principle and practicality. The proposal cuts across national sovereignty and subsidiarity. We believe that choices on taxation and expenditure are matters for each Member State. It is for each Member State to decide on the structure of its own tax system reflecting its historical traditions and social and economic priorities.
• As a practical measure, we do not believe that the proposal would render company taxation less complex or reduce business costs. Furthermore a CCCTB risks being inflexible in that all MS would have to agree to any change in corporate tax rules. The experience in the VAT code is especially relevant here. Despite a harmonised system since 1976, there are continual cases arising at the ECJ seeking to clarify the VAT rules and base. We do not believe that the proposal would of itself reduce compliance costs for companies as the optional system proposed would add to the administrative burden. There is no evidence that it would address issues such as competitiveness for companies. It would create uncertainties for companies by abandoning the universally accepted separate entity approach and allocating profits across Member States by reference to an untried arbitrary formula. In overall terms, we believe that this project would not be supportive of European business.
• Ireland is engaged with the Commission and with other Member States in a technical examination of the project strictly on a without prejudice basis. The issue of a common corporate tax base will have to be decided on policy and political grounds and not on the basis of technical analysis only. In that regard it is important to remember that no political decisions have been taken to date on this issue. That said we believe that a significant number of Member States remain sceptical about the Commission's plans.
• The Commission propose to bring forward a formal proposal on the CCCTB sometime in 2008. In that regard it is important to remember that the CCTB cannot be imposed on Member States. Unanimity is required for all decisions taken on taxation issues. Meanwhile Ireland will continue to work with the Commission in focussing efforts on achieving the structural economic reforms set out in the Lisbon agenda and the priorities set out under the EU Broad Economic Policy Guidelines; namely, growth, jobs and long term sustainability.”