GROUP TAXATION UNDER THE SYSTEM OF COMMON CONSOLIDATED CORPORATE TAX BASE

Abstract

The aim of the paper is to make a comparative analysis of the group taxation regimes, consolidation rules and loss-compensation rules in EU Member States and to discuss the regulation suggested in that area by European Commission in Common Consolidated Corporate Tax Base (hereinafter as CCCTB) draft directive. At the end, there should be also suggested solutions to questionable regulations. Theoretical background of the paper presents the reasons of the efforts of the European Commission to harmonize the area of corporate taxation. Second part of the paper presents the research of the rules which are used in individual EU member states for group taxation, consolidation and transfer of losses. Third part of the paper shows the rules comprised in CCCTB draft directive and discusses mainly the problems connected with setting of dual thresholds and rules for entering and leaving the group. All the aspects are analyzed with the use of concrete examples and schemes.