CCCTB vê o futuro adiado

A ideia de uma base tributável comum para as empresas na União Europeia não está a vingar com a facilidade que se esperaria. É a "Velha Europa" mais uma vez a funcionar. Isto de uma empresa com prejuízos fiscais num Estado-membro poder deduzi-los ao lucro tributável de outro coloca muitas questões que não vão ser fáceis de ultrapassar, como por exemplo, as diferenças nas administrações tributárias europeias no combate à evasão fiscal. Tive uma ideia peregrina para contornar este problema: a criação de uma inspecção tributária europeia!

Kovacs postpones CCCTB proposals
Joanna Faith

The European Commission has delayed the release of the highly anticipated legislative proposal on a common consolidated corporate tax base (CCCTB).

In a speech to the International Fiscal Association's annual congress, Commissioner Laszlo Kovacs said that while significant progress had been made on the proposal, there was still more work to do.

"I would rather present a perfectly elaborated and well justified product at the appropriate time than present an incomplete one just to meet an artificial deadline," Kovacs said.

In October 2007 Kovacs told the European Parliament he would present a proposal "after the summer break in 2008". And in April of this year, France pledged to push forward with plans for a CCCTB when its six-month presidency of the EU started in June. But in May rumours suggested the Commission had postponed the proposal date.

Despite opposition from member states including Ireland, Britain, Estonia and Slovakia, the Commission is committed to a CCCTB system. It claims the initiative would reduce compliance costs, omit the need to determine arm's length transfer prices for intra group transactions and provide a consolidation mechanism to offset profits and losses of the same company in different member states.

"It seems like political reality is intervening after Kovacs said 'business as usual' following Ireland's no vote to the Lisbon Treaty," said Peter Cussons, from PricewaterhouseCoopers in London.

Kovacs did not announce a new deadline for the proposal. Instead he said: "I remain fully committed to this project, and when the impact assessment and the proposal are properly ready I will present these to the College."

"It's unlikely there will be a directive under the French presidency," Cussons said. "Then there is a question mark over 2009. The Czech Republic takes over the presidency in the first half of the year and September is when the Commission is due to retire en masse."

But Cussons said that Jose Manuel Barroso, the president of the Commission, is hoping to be re-elected. "He wouldn't want any contentious documents on the table around the time of the election and a CCCTB would be one," he said.