BETA

Activities of Ramón JÁUREGUI ATONDO related to 2016/0337(CNS)

Plenary speeches (1)

Common Consolidated Corporate Tax Base - Common Corporate Tax Base (debate) ES
2016/11/22
Dossiers: 2016/0337(CNS)

Amendments (6)

Amendment 123 #
Proposal for a directive
Recital 5
(5) Many aggressive tax planning structures tend to feature in a cross-border context, which implies that the participating groups of companies possess a minimum of resources. On this premise, for reasons of proportionality, the rules on a common base should be mandatory only for companies which belong to a group of a substantial size. Fthe rules on a common base shall apply to companies operating in more that purpose, a size-related threshold should be fixed on the basis of the total consolidated revenue of a group which files consolidated financial statementn one Member State, although Member States may introduce a harmonised simplified procedure for SMEs. In addition, to ensure coherence between the two steps of the CCCTB initiative, the rules on a common base should be mandatory for companies which would be considered as a group should the full initiative materialise. In order to better serve the aim of facilitating trade and investment in the internal market, the rules on a common corporate tax base should also be available, as an option, to companies which do not meet those criteria.
2017/09/29
Committee: ECON
Amendment 130 #
Proposal for a directive
Recital 5 a (new)
(5a) Figures on Member States’ effective rates shall be based on homogeneous and comparable data provided by companies.
2017/09/29
Committee: ECON
Amendment 136 #
Proposal for a directive
Recital 6
(6) It is necessary to define the concept of a permanent establishment situated in the Union and belonging to a taxpayer who is resident for tax purposes within the Union. The aim would be to ensure that all concerned taxpayers share a common understanding and to exclude the possibility of a mismatch due to divergent definitions. On the contrary, it should not be seen as essential to have a common definition of permanent establishments situated in a third country, or in the Union but belonging to a taxpayer who is resident for tax purposes in a third country. ThThis notion of permanent establishment, which shall constitute grounds justifying taxation in a given juris dimensction, should better be left to bilateral tax treaties and national law due to its complicated interalso be adapted to the digital era, since many business models do not require physical infrastructure to conduct transactions with international agreemencustomers and make profits.
2017/09/29
Committee: ECON
Amendment 283 #
Proposal for a directive
Article 11
[...]deleted
2017/09/29
Committee: ECON
Amendment 303 #
Proposal for a directive
Article 13 – paragraph 2 – subparagraph 1
Exceeding borrowing costs shall be deductible in the tax year in which they are incurred for maximum of 30 10% of the taxpayer's earnings before interest, tax, depreciation and amortisation (‘EBITDA’) or for a maximum amount of EUR 3 000 000, whichever is higher, with a get-out clause based on the rates of interest the group pays to third parties.
2017/09/29
Committee: ECON
Amendment 333 #
Proposal for a directive
Article 42
1. profitable after having deducted its own losses pursuant to Article 41 may additionally deduct losses incurred, in the same tax year, by its immediate qualifying subsidiaries, as referred to in Article 3(1), or by permanent establishment(s) situated in other Member States. This loss relief shall be given for a limited period of time in accordance with paragraphs 3 and 4 of this Article. 2. proportion to the holding of the resident taxpayer in its qualifying subsidiaries as referred to in Article 3(1) and full for permanent establishments. In no case shaArticle 42 deleted Loss relief and recapture A resident taxpayer that is still tThe rdeduction of the tax base of tshall be in The resident taxpayer result in a negative amount. 3. back to its tax base, up to the amount previously deducted as a loss, any subsequent profits made by its qualifying subsidiaries as referred to in Article 3(1) or by its permanent establishments. 4. paragraphs 1 and 2 shall automatically be reincorporated into the tax base of the resident taxpayer in any of the following circumstances: (a) year after the losses became deductible, no profit has been reincorporated or the reincorporated profits do not correspond to the full amount of losses deducted; (b) referred to in Article 3(1) is sold, wound up or transformed into a permanent establishment; (c) establishment is sold, wound up or transformed into a subsidiary; (d) longer fulfils the requirements of Article 3(1).shall add Losses deducted pursuant to where, at the end of the fifth tax where the qualifying subsidiary as where the permanent where the parent company no
2017/09/29
Committee: ECON