- The CCCTB Rules on Leaving a Group
- Volume | Issue number
- 40 | 6/7
- Pages (from-to)
- Document type
- Faculty of Law (FdR)
- Amsterdam Center for Tax Law (ACTL)
The consolidation system proposed in the draft of the CCCTB Directive puts relationships between Member States on edge. This is clearly apparent in the rules that apply when a company leaves a group. In this article the leaving rules are examined. Although the leaving rules are claimed to be 'tailor-made', their effects are just as rough as the allocation of the consolidated profit according to the apportionment formula. It remains very much a question as to whether there are sufficient advantages to balance this approach.
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