Activities of Thomas HÄNDEL related to 2011/0058(CNS)
Shadow reports (1)
REPORT on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB) PDF (373 KB) DOC (550 KB)
Amendments (84)
Amendment 21 #
Proposal for a directive
Recital 1 a (new)
Recital 1 a (new)
(1a) On the other hand, the existence of 27 different corporate tax systems offers companies that operate across borders considerable scope for tax avoidance and tax evasion. This state of affairs is imposing a substantial burden on state budgets. It also runs counter to the priorities set in the Commission Communication of 3 March 2010 entitled 'Europe 2020 – A strategy for smart, sustainable and inclusive growth' and cannot be reconciled with the requirements of a social market economy.
Amendment 24 #
Proposal for a directive
Recital 1 b (new)
Recital 1 b (new)
(1b) National budgets are facing the ever more serious consequences of the ruinous tax competition among the EU Member States. Excessive state indebtedness is one of the main causes of the current economic and financial crisis. For that reason, the introduction of a lower limit of 25 % for corporation tax is both objectively justified and appropriate. Since the Member States' freedom to set taxes would not otherwise be affected, such a step would be consistent with the subsidiarity principle.
Amendment 34 #
Proposal for a directive
Recital 4
Recital 4
(4) A system allowingunder which companies to treat the Union as a single market for the purpose of corporate tax would facilitate cross-border activity for companies resident in the Union and would promote the objective of making the Union a more competitive location for investment internationally. Such a system would best be achieved by enablrequiring groups of companies with a taxable presence in more than one Member State to settle their tax affairs in the Union according to a single set of rules for calculation of the tax base and to deal with a single tax administration ('one-stop-shop'). These rules should also be made available to entities subject to corporate tax in the Union which do not form part of a group.
Amendment 40 #
Proposal for a directive
Recital 5
Recital 5
(5) Since differences in rates of taxation do not give rise to the same obstacles, the system (the Common Consolidated Corporate Tax Base (CCCTB)) need not fundamentally affect the discretion of Member States regarding their national rate(s) of company taxation, provided that the minimum rates of taxation set in the Union are not undercut.
Amendment 56 #
Proposal for a directive
Recital 8
Recital 8
(8) Since such a system is primarily designed to serve the needs of companies that operate across borders, it should be an optional scheme, accompany and to prevent tax evasion and tax avoidance more effectively, it should be a mandatory scheme, replacing the existing national corporate tax systems for the companies in question.
Amendment 63 #
Proposal for a directive
Recital 11
Recital 11
Amendment 65 #
Proposal for a directive
Recital 12
Recital 12
(12) Income consisting in interest and royalty payments should be taxable, with credit for withholding tax paid on such payments. Contrary to the case of dividends, there is no difficulty in computing such a credit, dividends, proceeds from the sale of shares in a company not belonging to the group and profits generated by plants located abroad should be taxable, with credit for withholding tax paid on such payments.
Amendment 67 #
Proposal for a directive
Recital 13
Recital 13
(13) Taxable revenues should be reduced by business expenses and certain other items. Deductible business expenses should normally include all costs relating to sales and expenses linked to the production, maintenance and securing of income. Deductibility should be extended to costs of research and development, provided that the money saved is used to procure or manufacture economic goods, and costs incurred in raising equity or debt for the purposes of the business. There should also be a list of non-deductible expenses.
Amendment 68 #
Proposal for a directive
Recital 15
Recital 15
(15) Taxpayers should be allowed to carry losses forward indefinitelyfor a maximum of seven years, but no loss carry-back should be allowed. The deductibility of losses carried forward should be limited to a set percentage of annual income. Since carry- forward of losses is intended to ensure that a taxpayer pays tax on its real income, there is nbut also to make state income from corporation tax more consistent and calculable and to prevent tax evasion to place a time limit on carry forwand fraud in connection with the setting-off against tax of revenue from plants and subsidiaries in third countries, a time limit and a minimum rate of taxation are necessardy. Loss carry back is relatively rare in the practice of the Member States, and leads to excessive complexity.
Amendment 72 #
Proposal for a directive
Recital 16
Recital 16
(16) Eligibility for consolidation (group membership) should be determined in accordance with a two-part test based on (i) control (more than 520% of voting rights) and (ii) ownership (more than 725% of equity) or rights to profits (more than 725% of rights giving entitlement to profit). Such a test ensures a highsufficient level of economic integration between group members, as indicated by a relation of control and a highcorresponding level of participation. The two thresholds should be met throughout the tax year; otherwise, the company should leave the group immediately. There should also be a nine- month minimum requirement for group membership.
Amendment 76 #
Proposal for a directive
Recital 18
Recital 18
(18) When withholding taxes are charged on interest, dividends and royalty payments made by taxpayers, the proceeds of such taxes should be shared according to the formula of that tax year. When withholding taxes are charged on dividends distributed by taxpayers, the proceeds of such taxes should not be shared since, contrary to interest and royalties, dividends have not led to a previous deduction borne by all group companies.
Amendment 77 #
Proposal for a directive
Recital 20
Recital 20
(20) The system should include a general anti-abuse rule, supplemented by measures designed to curb specific types of abusive practices. These measures should include limitationsa ban on the deductibility of interest paid to associated enterprises resident for tax purposes in a low-tax country outside the Union which does not exchange information with the Member State of the payer based on an agreement comparable to Council Directive 2011/16/EU concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation and taxation of insurance premiums and rules on controlled foreign companies.
Amendment 79 #
Proposal for a directive
Recital 21
Recital 21
(21) The formula for apportioning the consolidated tax base should comprise three equally weighted factors (labour, assets and sales). The labour factor should be computed on the basis of payroll and the number of employees (each item counting for half). The asset factor should consist of all fixed tangible assets. Intangibles and financial assets should be excluded from the formula due to their mobile nature and the risks of circumventing the system. The use of these factors is designed to gives appropriate weight to the interests of the Member State of origin. Finally, sales should be taken into account in order to ensure fair participation of the Member State of destination. TEvery three years those factors and weightings should be assessed in order to determine whether they ensure that profits are taxed where they are earned. As an exception to the general principle, where the outcome of the apportionment does not fairly represent the extent of business activity, a safeguard clause provides for an alternative method.
Amendment 83 #
Proposal for a directive
Recital 23
Recital 23
(23) Groups of companies should be able to deal with a single tax administration ('principal tax authority'), which should be that of the Member State in which the parent company of the group ('principal taxpayer') is resident for tax purposes. The activities of the Member States' tax authorities should be coordinated, supported and assessed by a European Tax Authority. This Directive should also lay down procedural rules for the administration of the system. It should also provide for an advance ruling mechanism. Audits should be initiated and coordinated by the principal tax authority but the authorities of any Member State in which a group member is subject to tax may requestinsist on the initiation of an audit. TDisputes between the competent authority of the Member State in which a group member is resident or established may challenge a decision ofand the principal tax authority concerning the notice to opt or an amended assessment before the courts of the Member State of the principal tax authorityshall be dealt with by the European Tax Authority, which is competent to hear appeals at first instance. Disputes between taxpayers and tax authorities should be dealt with by an administrative body which is competent to hear appeals at first instance according to the law of the Member State of the principal tax authority.
Amendment 94 #
Proposal for a directive
Article 1 – paragraph 1
Article 1 – paragraph 1
This Directive establishes a system for a common base for the taxation of certain companies and groups of companies and a minimum European rate of corporation tax and lays down rules relating to the calculation and use of that base.
Amendment 119 #
Proposal for a directive
Article 4 – paragraph 1 – point 15
Article 4 – paragraph 1 – point 15
(15) 'financial assets' means shares in affiliated undertakings, loans to affiliated undertakings, participating interests, loans to undertakings with which the company is linked by virtue of participating interests, investments held as fixed assets, other loans, and own shares to the extent that national law permitsuniform Union rules authorise their being shown in the balance sheet;
Amendment 125 #
Proposal for a directive
Chapter 3 – title
Chapter 3 – title
Amendment 128 #
Proposal for a directive
Article 6 – title
Article 6 – title
Amendment 134 #
Proposal for a directive
Article 6 – paragraph 1
Article 6 – paragraph 1
1. A company to which this Directive applies which is resident for tax purposes in a Member State may opt foshall be a taxpayer under the system provided for by this Directive under the conditions provided for therein.
Amendment 137 #
Proposal for a directive
Article 6 – paragraph 2
Article 6 – paragraph 2
2. A company to which this Directive applies which is not resident for tax purposes in a Member State may opt foshall be a taxpayer under the system provided for by this Directive under the conditions laid down therein in respect of a permanent establishment maintained by it in a Member State.
Amendment 145 #
Proposal for a directive
Article 7 – paragraph 1
Article 7 – paragraph 1
Where a company qualifies and opts for the system provided for by this Directive and is therefore a taxpayer it shall cease to be subject to the national corporate tax arrangements in respect of all matters regulated by this Directive unless otherwise stated.
Amendment 146 #
Proposal for a directive
Article 10a (new)
Article 10a (new)
Minimum rate of taxation A minimum rate of taxation of corporations shall apply on the territory of the European Union. The nominal rate must not, however, be less than 25 %. Member States shall otherwise be free to set rates.
Amendment 147 #
Proposal for a directive
Article 11 – paragraph 1 – point c
Article 11 – paragraph 1 – point c
Amendment 150 #
Proposal for a directive
Article 11 – paragraph 1 – point d
Article 11 – paragraph 1 – point d
d) proceeds from a disposal of shares;eleted
Amendment 152 #
Proposal for a directive
Article 11 – paragraph 1 – point e
Article 11 – paragraph 1 – point e
Amendment 153 #
Proposal for a directive
Article 12 – paragraph 1
Article 12 – paragraph 1
Deductible expenses shall include all costs of sales and expenses net of deductible value added tax incurred by the taxpayer with a view to obtaining or securing income, including costs of research and development, provided the money saved is used to procure or manufacture economic goods, and costs incurred in raising equity or debt for the purposes of the business.
Amendment 159 #
Proposal for a directive
Article 39 – paragraph 1
Article 39 – paragraph 1
1. Fixed assets other than those referred to in Articles 36 and 40 shall be depreciated together in one asset pool at an annual rate of 250% of the depreciation base.
Amendment 160 #
Proposal for a directive
Article 43 – paragraph 1
Article 43 – paragraph 1
1. A loss incurred by a taxpayer or a permanent establishment of a non-resident taxpayer in a fiscal year may be deducted in the seven subsequent tax years, unless otherwise provided by this Directive. Above a threshold figure of EUR 1 million, the loss carried forward shall be limited to 60% of annual income in excess of EUR 1 million.
Amendment 165 #
Proposal for a directive
Article 44 – paragraph 1
Article 44 – paragraph 1
When a taxpayer opts to applis covered by the system provided for by this Directive, all assets and liabilities shall be recognised at their value as calculated according to national tax rules immediately prior to the date on which it begins to apply the system, unless otherwise stated in this Directive.
Amendment 168 #
Proposal for a directive
Article 46 – paragraph 1
Article 46 – paragraph 1
Revenues and expenses which pursuant to Article 24(2) and (3) are considered to have accrued or been incurred before the taxpayer opted intowas covered by the system provided for by this Directive but were not yet included in the tax base under the national corporate tax law previously applicable to the taxpayer shall be added to or deducted from the tax base, as the case may be, in accordance with the timing rules of national law.
Amendment 172 #
Proposal for a directive
Article 46 – paragraph 2
Article 46 – paragraph 2
Revenues which were taxed under national corporate tax law before the taxpayer opted intowas covered by the system in an amount higher than that which would have been included in the tax base under Article 24(2) shall be deducted from the tax base.
Amendment 173 #
Proposal for a directive
Article 47 – paragraph 1
Article 47 – paragraph 1
1. Provisions, pension provisions and bad- debt deductions provided for in Articles 25, 26 and 27 shall be deductible only to the extent that they arise from activities or transactions carried out after the taxpayer opted intowas covered by the system provided for by this Directive.
Amendment 176 #
Proposal for a directive
Article 47 – paragraph 2
Article 47 – paragraph 2
2. Expenses incurred in relation to activities or transactions carried out before the taxpayer opted intowas covered by the system but for which no deduction had been made shall be deductible.
Amendment 181 #
Proposal for a directive
Article 48 – paragraph 1
Article 48 – paragraph 1
Where a taxpayer incurred losses before opting into the system provided for by this Directive applied to it which could be carried forward under the applicable national law but had not yet been set off against taxable profits, those losses may be deducted from the tax base to the extent provided for under that national law.
Amendment 188 #
Proposal for a directive
Article 49 – paragraph 1
Article 49 – paragraph 1
When a taxpayer leavesthe legal form of an undertaking changes so that it is no longer covered by the provisions of the system provided for by this Directive, its assets and liabilities shall be recognised at their value as calculated according to the rules of the system, unless otherwise stated in this Directive.
Amendment 194 #
Proposal for a directive
Article 50 – paragraph 1
Article 50 – paragraph 1
When a taxpayer leavesthe legal form of an undertaking changes so that it is no longer covered by the provisions of the system provided for by this Directive, its asset pool under the system provided for by this Directive shall be recognised, for the purpose of the national tax rules subsequently applicable, as one asset pool which shall be depreciated on the declining balance method at an annual rate of 25%.
Amendment 199 #
Proposal for a directive
Article 51 – paragraph 1
Article 51 – paragraph 1
Amendment 203 #
Proposal for a directive
Article 52 – paragraph 1
Article 52 – paragraph 1
Amendment 212 #
Proposal for a directive
Article 54 – paragraph 1 – point a
Article 54 – paragraph 1 – point a
(a) a right to exercise more than 520% of the voting rights;
Amendment 214 #
Proposal for a directive
Article 54 – paragraph 1 – point b
Article 54 – paragraph 1 – point b
(b) an ownership right amounting to more than 725% of the company’s capital or more than 725% of the rights giving entitlement to profit.
Amendment 217 #
Proposal for a directive
Article 54 – paragraph 2 – point b
Article 54 – paragraph 2 – point b
(b) entitlement to profit and ownership of capital shall be calculated by multiplying the interests held in intermediate subsidiaries at each tier. Ownership rights amounting to 725% or less held directly or indirectly by the parent company, including rights in companies resident in a third country, shall also be taken into account in the calculation.
Amendment 249 #
Proposal for a directive
Article 72
Article 72
Amendment 252 #
Proposal for a directive
Article 73
Article 73
Amendment 271 #
Proposal for a directive
Article 81 – paragraph 1 – point a
Article 81 – paragraph 1 – point a
(a) a tax on profits is provided for, under the general regime in the third country, at a statutory corporate tax rate lower than 40% of the average statutory corporate tax rate applicable in the Member Statesthe minimum corporate tax rate provided for by this Directive;
Amendment 275 #
Proposal for a directive
Article 81 – paragraph 3 – introductory part
Article 81 – paragraph 3 – introductory part
3. Notwithstanding paragraph 1, iInterest paid to an entity resident in a third country with which there is no agreement on the exchange of information comparable to the exchange of information on request provided for in Directive 2011/16/EU shall be deductible, in an amount not exceeding that which would be stipulated between independent enterprises, where one of the following conditions is met:not be deductible.
Amendment 276 #
Proposal for a directive
Article 81 – paragraph 3 – point a
Article 81 – paragraph 3 – point a
Amendment 277 #
Proposal for a directive
Article 81 – paragraph 3 – point b
Article 81 – paragraph 3 – point b
Amendment 278 #
Proposal for a directive
Article 81 – paragraph 3 – point c
Article 81 – paragraph 3 – point c
Amendment 279 #
Proposal for a directive
Article 82 – paragraph 1 – introductory part
Article 82 – paragraph 1 – introductory part
1. The tax base shall, proportionately, include the non- distributed income of an entity resident in a third country where the following conditions are met:
Amendment 280 #
Proposal for a directive
Article 82 – paragraph 1 – point a
Article 82 – paragraph 1 – point a
(a) the taxpayer by itself, or together with its associated enterprises, holds a direct or indirect participation of more than 520% of the voting rights, or owns more than 520% of capital or is entitled to receive more than 520% of the profits of that entity;
Amendment 281 #
Proposal for a directive
Article 82 – paragraph 1 – point b
Article 82 – paragraph 1 – point b
(b) under the general regime in the third country, profits are taxable at a statutory corporate tax rate lower than 40% of the averagthe statutory minimum corporate tax rate applicable in the Member States, or the entity is subject to a special regime that allows for a substantially lower level of taxation than that of the general regime;
Amendment 298 #
Proposal for a directive
Article 90 – paragraph 3
Article 90 – paragraph 3
3. The definition of an employee shall be determined by the national law of the Member State where the employment is exercisedat EU level.
Amendment 307 #
Proposal for a directive
Article 94 – paragraph 1
Article 94 – paragraph 1
1. Land and other non-depreciable fixed tangible assets shall be valued at their original costcurrent market value.
Amendment 325 #
Proposal for a directive
Article 104 – title
Article 104 – title
Notice to optconcerning the applicability of the system
Amendment 327 #
Proposal for a directive
Article 104 – paragraph 1 – subparagraph 1
Article 104 – paragraph 1 – subparagraph 1
A single taxpayer shall opt forbe subject to the system provided for by this Directive by giving notice toas a result of a notification to that effect by the competent authority of the Member State in which it is resident or, in respect of a permanent establishment of a non-resident taxpayer, that establishment is situated. In the case of a group, the principal taxpayer authority shall give notice, on behalf of the group, to the principal tax authoritythe notification.
Amendment 329 #
Proposal for a directive
Article 104 – paragraph 1 – subparagraph 2
Article 104 – paragraph 1 – subparagraph 2
Such notice shall be given at least three months before the beginning of the tax year in which the taxpayer or the group wishes required to begin applying the system.
Amendment 331 #
Proposal for a directive
Article 104 – paragraph 2
Article 104 – paragraph 2
2. The notice to opt shall cover all group members. However, shipping companies subject to a special taxation regime may be excluded from the group.
Amendment 333 #
Proposal for a directive
Article 104 – paragraph 3
Article 104 – paragraph 3
3. The principal tax authority shall transmit the notice to opt immediately to the competent authorities of all Member States in which group members are resident or established. Those authorities may submit to the principal tax authority, within one month of the transmission, their views and any relevant information on the validity and scope of the notice to opt.
Amendment 339 #
Proposal for a directive
Article 105 – paragraph 1
Article 105 – paragraph 1
1. When the notice to opt has been acceptdelivered, a single taxpayer or a group, as the case may be, shall apply the system provided for by this Directive for five tax years. Following the expiry of that initial term, the single taxpayer or the group shall continue to apply the system for successive terms of three tax years unless the tax authority gives notice of termination. A notice of termination may be given by a taxpayer to its competentthe tax authority or, in the case of a group, by the principal taxpayer to the principal tax authority in the three months preceding the end of the initial term or of a subsequent term.
Amendment 343 #
Proposal for a directive
Article 105 – paragraph 2
Article 105 – paragraph 2
2. Where a taxpayer or a non-taxpayer joins a group, the term of the group shallDoes not be affected. Where a group joins another group or two or more groups merge, the enlarged group shall continue to apply the system until the later of the expiry dates of the terms of the groups, unless exceptional circumstances make it more appropriate to apply a shorter period the English version.
Amendment 349 #
Proposal for a directive
Article 106 – title
Article 106 – title
Information in the notice to opt
Amendment 351 #
Proposal for a directive
Article 106 – paragraph 1 – introductory part
Article 106 – paragraph 1 – introductory part
The following information shall be included in the notice to opt:
Amendment 358 #
Proposal for a directive
Article 106 – paragraph 2
Article 106 – paragraph 2
The Commission mayshall adopt an act establishing a standard form of the notice to opt. That implementing act shall be adopted in accordance with the examination procedure referred to in Article 131(2).
Amendment 363 #
Proposal for a directive
Article 107 – title
Article 107 – title
Control of the notice to opt
Amendment 365 #
Proposal for a directive
Article 107 – paragraph 1
Article 107 – paragraph 1
1. The competent authority to which the notice to opt is validly submitted shall examine whether, on the basis of the information contained in the notice, the group fulfils the requirements of this Directive. Unless the notice is rejected within three months of its receipt, it shall be deemed to have been accepted.
Amendment 367 #
Proposal for a directive
Article 107 – paragraph 2
Article 107 – paragraph 2
2. Provided that the taxpayer has fully disclosed all relevant information in accordance with Article 106, any subsequent determination that the disclosed list of group members is incorrect shall not invalidate the notice to opt. The notice shall be corrected, and all other necessary measures shall be taken, from the beginning of the tax year when the discovery is made. Where there has not been full disclosure, the principal tax authority, in agreement with the other competent authorities concerned, may invalidate the original notice to opt.
Amendment 369 #
Proposal for a directive
Article 108 – paragraph 2
Article 108 – paragraph 2
2. In the year in which it joins an existing group, a taxpayer shall bring its tax year into line with that of the group. The apportioned share of the taxpayer for that tax year shall be calculated proportionately having regard to the number of calendar months during which the company belonged to the groupDoes not affect the English version.
Amendment 370 #
Proposal for a directive
Article 108 – paragraph 4
Article 108 – paragraph 4
4. Where a single taxpayer joins a group, it shall be treated as though its tax year terminated on the day before joiningDoes not affect the English version.
Amendment 379 #
Proposal for a directive
Article 115 – title
Article 115 – title
Central authority for the coordination and management of a central data base
Amendment 380 #
Proposal for a directive
Article 115 – paragraph -1 (new)
Article 115 – paragraph -1 (new)
A central tax authority for the European Union shall be established. It shall coordinate the activities of the tax authorities of the Member States in accordance with this Directive and shall manage a central data base.
Amendment 381 #
Proposal for a directive
Article 115 – paragraph 1
Article 115 – paragraph 1
The consolidated tax return and supporting documents filed by the principal taxpayer shall be stored on athis central data base, to which all the competent authorities shall have access. The central data base shall be regularly updated with all further information and documents and all decisions and notices issued by the principal tax authority.
Amendment 383 #
Proposal for a directive
Article 116 – paragraph 2
Article 116 – paragraph 2
In exceptional circumstances the competent tax authorities of the Member States in which the members of a group are resident or in which they have a permanent establishment may, within six months of the notice to opt or within six months of a reorganisation involving the principal taxpayer, decide by common agreement that a taxpayer other than the taxpayer designated by the group shall be the principal taxpayer.
Amendment 390 #
Article 122 – paragraph 1 – subparagraph 1
The principal tax authority may initiate and coordinate audits of group members. They shall be coordinated by the European tax authority. An audit may also be initiated on the request of a competent authority or the European tax authority.
Amendment 391 #
Proposal for a directive
Article 122 – paragraph 3
Article 122 – paragraph 3
3. The principalEuropean tax authority shall compile the results of all audits.
Amendment 393 #
Proposal for a directive
Article 123 – paragraph 1
Article 123 – paragraph 1
1. Where the competent authority of the Member State in which a group member is resident or established disagrees with a decision of the principal tax authority made pursuant to Articles 107 or Article 114 paragraphs (3), (5) or (6) second subparagraph, it may challenge that decision before the courts of the Member State of the principal tax authority within a period of three monthsin the first instance before the European tax authority and thereafter before the Court of Justice of the European Union.
Amendment 394 #
Proposal for a directive
Article 123 – paragraph 2
Article 123 – paragraph 2
Amendment 398 #
Proposal for a directive
Article 124 – paragraph 1 – subparagraph 1 – point a
Article 124 – paragraph 1 – subparagraph 1 – point a
(a) a decision rejecting a notice to opt;
Amendment 403 #
Proposal for a directive
Article 127 – paragraph 2
Article 127 – paragraph 2
2. As soon as the Commission adopts a delegated act, it shall notify it to the European Parliament and the Council.
Amendment 404 #
Proposal for a directive
Article 128 – paragraph 1
Article 128 – paragraph 1
1. The delegation of powers referred to in Articles 2, 14, 34 and 42 may be revoked at any time by the European Parliament or by the Council.
Amendment 405 #
Proposal for a directive
Article 129 – paragraph 1
Article 129 – paragraph 1
1. The European Parliament and the Council may object to a delegated act within a period of three months from the date of notification.
Amendment 406 #
Proposal for a directive
Article 129 – paragraph 2 – subparagraph 1
Article 129 – paragraph 2 – subparagraph 1
If, on the expiry of this period, neither the European Parliament nor the Council has not objected to the delegated act, it shall be published in the Official Journal of the European Union and shall enter into force on the date stated therein.
Amendment 407 #
Proposal for a directive
Article 129 – paragraph 2 – subparagraph 2
Article 129 – paragraph 2 – subparagraph 2
The delegated act may be published in the Official Journal of the European Union and enter into force before the expiry of that period if the European Parliament and the Council hasve informed the Commission of itstheir intention not to raise objections.
Amendment 408 #
Proposal for a directive
Article 130
Article 130
Amendment 414 #
Proposal for a directive
Article 133 – paragraph 1
Article 133 – paragraph 1
The Commission shall, fivthree years after the entry into force of this Directive, review its application and report to the European Parliament and the Council on the operation of this Directive. The report shall in particular include an analysis of the impact of the mechanism set up in Chapter XVI of this Directive on the distribution of the tax bases between the Member States and of the consolidation provisions.