The CCCTB Rules on Leaving a Group

Authors
Publication date 2012
Journal Intertax
Volume | Issue number 40 | 6/7
Pages (from-to) 421-430
Organisations
  • Faculty of Law (FdR) - Amsterdam Center for Tax Law (ACTL)
Abstract 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.
Document type Article
Language English
Published at http://www.kluwerlawonline.com/document.php?id=TAXI2012041
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