Activities of Ramón JÁUREGUI ATONDO related to 2016/0337(CNS)
Plenary speeches (1)
Common Consolidated Corporate Tax Base - Common Corporate Tax Base (debate) ES
Amendments (6)
Amendment 123 #
Proposal for a directive
Recital 5
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.
Amendment 130 #
Proposal for a directive
Recital 5 a (new)
Recital 5 a (new)
(5a) Figures on Member States’ effective rates shall be based on homogeneous and comparable data provided by companies.
Amendment 136 #
Proposal for a directive
Recital 6
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.
Amendment 283 #
Proposal for a directive
Article 11
Article 11
Amendment 303 #
Proposal for a directive
Article 13 – paragraph 2 – subparagraph 1
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.
Amendment 333 #
Proposal for a directive
Article 42
Article 42