| Abstract [eng] |
This master thesis provides analysis of the topic of the common corporate tax base initiative by examining the European Commission's proposals for directives, other legislation, communications, scholarly findings and impact assessment studies. The thesis focuses on the regulatory aspects of the proposed common and consolidated corporate tax base at the European Union level, its historical development, its impact on corporate tax bases and tax competition. It seeks to find a means of reaching a compromise between the Member States of the European Union on the adoption of this initiative. The thesis analyzes the legal basis for the harmonization of the corporate tax base, past proposals, developments and the reasons for its stagnation. It analyses the regulation of the directives proposed by the Commission, which should be carried over into future proposals. The scope, principles, calculation of the tax base, the growth and investment incentive allowance, the deduction of R&D expenses, loss relief, depreciation of fixed assets and the key aspects of consolidation of the corporate tax base are examined in detail. The Commission's forthcoming draft directive "Business in Europe: A Framework for Income Taxation" (BEFIT), which is intended to be a continuation of the CCCTB initiative, is discussed. The paper attempts to forecast the prospects for a common corporate tax initiative. |
