| Abstract [eng] |
The European Commission on 16 March 2011 proposed a harmonized system for the tax base calculation of companies operating in the EU. The proposed Common Consolidated Corporate Tax Base (CCCTB) indicates that businesses would benefit from a \"one-stop-shop\" system for filing their tax returns and would be able to consolidate all the profits and losses they incur across the EU. Member States would maintain their full sovereign right to set their own corporate tax rate. However, many Member States are against this new system as they think that CCCTB does not meet principles of subsidiarity and proportionality and is not available to reach its goals. Therefore, the hypothesis of this Master Thesis was formulated that CCCTB is an appropriate way to reach company tax harmonization in the EU and abolish obstacles which arise because of 27 different taxation systems in EU. After comprehensive analysis of major company taxation obstacles in the first chapter, these main barriers were identified: double taxation, additional compliance cost, over-taxation which arise in cross-border activities. The main measures such as Parent-Subsidiary Directive, Merger Directive, Interest and Royalties Directive and Arbitration Convention designed to cope with these barriers were discussed and the main challenges needed to solve by CCCTB were formulated. Proposed Directive and main elements of CCCTB were investigated in the second chapter. As there is a disagreement between Member States regarding to adoption of CCCTB Directive, procedure of enhanced cooperation was introduced. Different alternatives for CCCTB were discussed. Firstly, as the optional CCCTB system was chosen to implement, the main advantages and disadvantages of optional and compulsory character were analyzed. Secondly, as CCCTB harmonizes only base, the possibilities of rate harmonization were investigated. Besides, the former suggestions by the Commission, such as Home State Taxation, Compulsory Harmonized Tax Base and European Union Corporate Income Tax and the reasons of their refusal were investigated. The third part of this Master Thesis introduced Formulary Apportionment method for taxable profits calculation which was compared to similar methods used in USA and Canada. Lastly, the impact for Lithuanian companies of this method adoption was evaluated. After this analysis, hypothesis that CCCTB is an appropriate way to reach company tax harmonization in the EU and abolish obstacles which arise because of 27 different taxation systems in EU was approved. |
