BETA


2016/0336(CNS) Common consolidated corporate tax base (CCCTB)

Progress: Awaiting final decision

RoleCommitteeRapporteurShadows
Lead ECON LAMASSOURE Alain (icon: PPE PPE) BAYET Hugues (icon: S&D S&D), LOONES Sander (icon: ECR ECR), WIERINCK Lieve (icon: ALDE ALDE), JOLY Eva (icon: Verts/ALE Verts/ALE), VALLI Marco (icon: EFDD EFDD), KAPPEL Barbara (icon: ENF ENF)
Committee Opinion IMCO
Committee Opinion JURI REGNER Evelyn (icon: S&D S&D) Constance LE GRIP (icon: PPE PPE), Jiří MAŠTÁLKA (icon: GUE/NGL GUE/NGL), Jens ROHDE (icon: ALDE ALDE)
Lead committee dossier:
Legal Basis:
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Events

2019/01/11
   FR_ASSEMBLY - Contribution
Documents
2018/05/24
   European Commission - Commission response to text adopted in plenary
Documents
2018/03/15
   EP - Decision by Parliament
Details

The European Parliament adopted by 438 votes to 145, with 69 abstentions, following Parliament’s consultation, a legislative resolution on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB).

Parliament approved the Commission proposal subject to the following amendments:

Members noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models.

Subject matter : Parliament called for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system.

Once implemented in all Member States, a CCCTB would ensure that taxes are paid where profits are generated and where companies have permanent establishment . Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning.

The amended text stressed the importance of ensuring the simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base. Moreover, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States . If the Council fails to adopt a unanimous decision on the proposal to establish a CCCTB, the Commission should issue a new proposal in accordance with the ordinary legislative procedure. As a last resort, an enhanced cooperation should be initiated by Member States.

Scope : the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years .

Digital presence in a country to determine taxable profits : the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity , whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment , in a Member State.

Effect of consolidation : the tax basis of a consolidated group shall be determined as if it were one single entity . For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group.

Where the consolidated tax base is negative, the loss shall be carried forward and be set off against the next positive consolidated tax base for a maximum period of five years.

Apportionment of the common consolidated tax base : in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities.

The volume of personal data collected pursuant to the data factor shall be measured at the end of the tax year in each Member State.

Informing the European Parliament : the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

Compensation mechanism : in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a temporary compensation mechanism, operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years.

Informing the European Parliament : Members suggested that the European Parliament organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

Implementation report and review : the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.

Text adopted by Parliament, 1st reading/single reading

Documents
2018/03/15
   EP - Results of vote in Parliament
2018/03/14
   EP - Debate in Parliament
Documents
2018/03/01
   EP - Committee report tabled for plenary, 1st reading/single reading
Details

The Committee on Economic and Monetary Affairs adopted, following Parliament’s consultation , the report by Alain LAMASSOURE (EPP, FR) on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB).

The committee recommended that the European Parliament approve the Commission proposal subject to the following amendments:

The report noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models.

Subject matter : Members are calling for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system.

Once implemented in all Member States, a CCCTB would ensure that taxes are paid the internal market. Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning.

Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, it is very important to ensure simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base . Because such a change of regime is a significant step in the completion of the internal market, it needs flexibility in order to be properly executed from the outset. Hence, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States .

Scope : the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years.

Tax residence : the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity , whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment , in a Member State.

Effect of consolidation : the tax basis of a consolidated group shall be determined as if it were one single entity . For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group.

Apportionment of the common consolidated tax base : in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities.

Informing the European Parliament : the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

Compensation mechanism : in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a dedicated compensation mechanism , operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years.

Implementation report and review : the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.

Committee report tabled for plenary, 1st reading/single reading

Documents
2018/02/21
   EP - Vote in committee
2017/10/04
   European Parliament - Committee opinion
Documents
2017/09/29
   European Parliament - Amendments tabled in committee
Documents
2017/07/13
   European Parliament - Committee draft report
Documents
2017/05/31
   RO_CHAMBER - Contribution
Documents
2017/05/16
   European Parliament - Amendments tabled in committee
Documents
2017/04/04
   CY_PARLIAMENT - Contribution
Documents
2017/03/14
   CZ_SENATE - Contribution
Documents
2017/02/23
   SE_PARLIAMENT - Reasoned opinion
Documents
2017/02/08
   IE_SENATE - Reasoned opinion
Documents
2017/02/08
   IE_CHAMBER - Reasoned opinion
Documents
2017/02/06
   NL_CHAMBER - Reasoned opinion
Documents
2017/01/24
   AT_BUNDESRAT - Contribution
Documents
2017/01/23
   MT_PARLIAMENT - Reasoned opinion
Documents
2017/01/17
   UK_HOUSE-OF-COMMONS - Contribution
Documents
2017/01/13
   LU_CHAMBER - Reasoned opinion
Documents
2017/01/12
   NL_SENATE - Reasoned opinion
Documents
2016/12/22
   DE_BUNDESRAT - Contribution
Documents
2016/12/22
   PT_PARLIAMENT - Contribution
Documents
2016/12/21
   ES_PARLIAMENT - Contribution
Documents
2016/12/06
   CSL - Debate in Council
2016/12/06
   CSL - Council Meeting
2016/11/28
   EP - REGNER Evelyn (S&D) appointed as rapporteur in JURI
2016/11/24
   EP - Committee referral announced in Parliament
2016/11/22
   EP - LAMASSOURE Alain (PPE) appointed as rapporteur in ECON
2016/10/26
   European Commission - Document attached to the procedure
2016/10/26
   European Commission - Document attached to the procedure
2016/10/25
   European Commission - Legislative proposal
Details

PURPOSE: to present a proposal for a re-launched Common Consolidated Corporate Tax Base (CCCTB) to ensure a corporate tax system that encourages growth and fairness in the internal market.

PROPOSED ACT: Council Directive.

ROLE OF THE EUROPEAN PARLIAMENT: the Council adopts the act after consulting Parliament but without being obliged to follow the latter’s opinion.

BACKGROUND: currently, businesses with cross-border activity have to comply with up to 28 divergent corporate tax systems. Generally, corporate income is taxed at national level, but the economic environment has become more globalised, mobile and digital. Business models and corporate structures are more complex, making it easier to shift profits.

In March 2011, the Commission proposed a directive for a Common Consolidated Corporate Tax Base (CCCTB). The proposal, which is still pending in Council, aims to provide companies with a single set of corporate tax rules for doing business across the internal market, thereby facilitating their cross-border activity.

The discussions in Council since 2011 have shown that the CCCTB proposal is unlikely to get adopted, in its entirety, without a staged approach. The Commission, in its action plan of June 2015, advocated a step-by-step approach to the CCCTB .

Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, the Commission considers it necessary to divide the ambitious CCCTB initiative into two separate proposals. It proposes, at a first stage, rules on a common corporate tax base , before addressing, at a second stage, the issue of consolidation.

This proposal for a Directive focuses on the so-called 'second step' of the staged approach (consolidation) , i.e. after the elements of the common base have politically been agreed. Until this is achieved, the 2011 proposal for a CCCTB will remain pending for examination in Council. The Commission will submit the two proposals, i.e. for a common corporate tax base and a CCCTB, simultaneously and as part of a single initiative. The proposal of 2011 will be withdrawn at the same time as the Commission adopts the new proposals.

This initiative on re-launching the CCCTB features prominently in the Commission’s larger project in the field of fairer taxation. It will be presented at the same time as the proposal for a directive on hybrid mismatches involving third countries (which will amend the Directive tax avoidance) and a directive on dispute settlement.

IMPACT ASSESSMENT: the main policy option that has been considered is a proposal for a common consolidated corporate tax base. A key choice to be made relates to the scope of such a tax base, i.e. to whom it would apply.

Assessing the different options has led to a preferred option: a CCCTB mandatory for large companies, equipped with an 'Allowance for Growth and Investment' and with an allowance for research and development expenses.

The anticipated economic benefits of the proposal are positive, leading to an increase in investment and employment of up to 3.4% and 0.6%, respectively. Overall, growth would increase by up to 1.2%.

CONTENT: the proposal is the 'second step' in a staged approach towards an EU-wide corporate tax system with cross-border consolidation of the tax results amongst members of the same group.

Scope: in contrast to the proposal of 2011, which laid down an optional system for all, this proposal will be mandatory for groups of companies beyond a certain size (whose consolidated turnover is above EUR 750 million). The threshold is in line with the approach taken in other EU initiatives to counter tax avoidance.

At the same time, the common rules will be available, as an option, to a wide scope of groups that fall short of the size threshold. This allows SMEs and micro-enterprises the opportunity to benefit from the advantages of a CCCTB without making it compulsory for this set of companies.

Definition of group: (unchanged compared to the proposal of 2011): eligibility for the consolidated tax group will be determined in accordance with a two-part test based on (i) control (more than 50% of voting rights) and (ii) ownership (more than 75 % of equity) or rights to profits (more than 75 % of rights giving entitlement to profit). These thresholds must be met throughout the tax year; otherwise, the failing company will have to leave the group immediately.

Business reorganisations and taxation of losses and unrealised capital gains : the proposed framework chiefly involves the treatment of losses and unrealised capital gains on entering and leaving the group.

There are rules to deal with unrealised capital gains which have accrued to fixed assets where the assets are disposed of within a short period after their entry into, or exit from, a group. A Member State (in the case of an entry into a group) or the group (in the case of an exit from a group) are given the right to tax underlying capital gains to the extent those were created in their tax jurisdiction. Moreover, the tax treatment of capital gains engrained in self-generated intangible assets calls for a customised approach, which will involve assessing them on the basis of a suitable proxy, that is to say, research and development , and marketing and advertising costs over a specified period.

Withholding taxes (unchanged compared to the proposal of 2011): the proceeds of withholding taxes charged on interest and royalty payments made by taxpayers will be shared according to the formula of that tax year. Withholding taxes charged on dividends will not be shared.

Preventing circumvention of tax exemptions (unchanged compared to the proposal of 2011): the tax exemption in favour of disposals of shares will be disallowed if this is illegitimately extended to sales of assets other than shares.

Formula for apportionment : one of the principal elements of the proposal is the formulary apportionment, comprised of three equally weighted factors (i.e. labour, assets and sales by destination). This combination reflects a balanced approach to distributing taxable profits amongst eligible Member States.

Administrative procedures : in contrast to the proposal of 2011, the common administrative rules are limited to the consolidated group.

Groups will deal with a single tax administration in the EU ('principal tax authority' or 'one-stop-shop'.) This will be based in the Member State where the parent company of the group ('principal taxpayer') is resident for tax purposes. Audits will be initiated and coordinated by the principal tax authority.

DELEGATED ACTS: the proposal contains provisions empowering the Commission to adopt delegated acts in accordance with Article 290 of the Treaty of the Functioning of the European Union.

Legislative proposal

2016/10/25
   EC - Legislative proposal published
Details

PURPOSE: to present a proposal for a re-launched Common Consolidated Corporate Tax Base (CCCTB) to ensure a corporate tax system that encourages growth and fairness in the internal market.

PROPOSED ACT: Council Directive.

ROLE OF THE EUROPEAN PARLIAMENT: the Council adopts the act after consulting Parliament but without being obliged to follow the latter’s opinion.

BACKGROUND: currently, businesses with cross-border activity have to comply with up to 28 divergent corporate tax systems. Generally, corporate income is taxed at national level, but the economic environment has become more globalised, mobile and digital. Business models and corporate structures are more complex, making it easier to shift profits.

In March 2011, the Commission proposed a directive for a Common Consolidated Corporate Tax Base (CCCTB). The proposal, which is still pending in Council, aims to provide companies with a single set of corporate tax rules for doing business across the internal market, thereby facilitating their cross-border activity.

The discussions in Council since 2011 have shown that the CCCTB proposal is unlikely to get adopted, in its entirety, without a staged approach. The Commission, in its action plan of June 2015, advocated a step-by-step approach to the CCCTB .

Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, the Commission considers it necessary to divide the ambitious CCCTB initiative into two separate proposals. It proposes, at a first stage, rules on a common corporate tax base , before addressing, at a second stage, the issue of consolidation.

This proposal for a Directive focuses on the so-called 'second step' of the staged approach (consolidation) , i.e. after the elements of the common base have politically been agreed. Until this is achieved, the 2011 proposal for a CCCTB will remain pending for examination in Council. The Commission will submit the two proposals, i.e. for a common corporate tax base and a CCCTB, simultaneously and as part of a single initiative. The proposal of 2011 will be withdrawn at the same time as the Commission adopts the new proposals.

This initiative on re-launching the CCCTB features prominently in the Commission’s larger project in the field of fairer taxation. It will be presented at the same time as the proposal for a directive on hybrid mismatches involving third countries (which will amend the Directive tax avoidance) and a directive on dispute settlement.

IMPACT ASSESSMENT: the main policy option that has been considered is a proposal for a common consolidated corporate tax base. A key choice to be made relates to the scope of such a tax base, i.e. to whom it would apply.

Assessing the different options has led to a preferred option: a CCCTB mandatory for large companies, equipped with an 'Allowance for Growth and Investment' and with an allowance for research and development expenses.

The anticipated economic benefits of the proposal are positive, leading to an increase in investment and employment of up to 3.4% and 0.6%, respectively. Overall, growth would increase by up to 1.2%.

CONTENT: the proposal is the 'second step' in a staged approach towards an EU-wide corporate tax system with cross-border consolidation of the tax results amongst members of the same group.

Scope: in contrast to the proposal of 2011, which laid down an optional system for all, this proposal will be mandatory for groups of companies beyond a certain size (whose consolidated turnover is above EUR 750 million). The threshold is in line with the approach taken in other EU initiatives to counter tax avoidance.

At the same time, the common rules will be available, as an option, to a wide scope of groups that fall short of the size threshold. This allows SMEs and micro-enterprises the opportunity to benefit from the advantages of a CCCTB without making it compulsory for this set of companies.

Definition of group: (unchanged compared to the proposal of 2011): eligibility for the consolidated tax group will be determined in accordance with a two-part test based on (i) control (more than 50% of voting rights) and (ii) ownership (more than 75 % of equity) or rights to profits (more than 75 % of rights giving entitlement to profit). These thresholds must be met throughout the tax year; otherwise, the failing company will have to leave the group immediately.

Business reorganisations and taxation of losses and unrealised capital gains : the proposed framework chiefly involves the treatment of losses and unrealised capital gains on entering and leaving the group.

There are rules to deal with unrealised capital gains which have accrued to fixed assets where the assets are disposed of within a short period after their entry into, or exit from, a group. A Member State (in the case of an entry into a group) or the group (in the case of an exit from a group) are given the right to tax underlying capital gains to the extent those were created in their tax jurisdiction. Moreover, the tax treatment of capital gains engrained in self-generated intangible assets calls for a customised approach, which will involve assessing them on the basis of a suitable proxy, that is to say, research and development , and marketing and advertising costs over a specified period.

Withholding taxes (unchanged compared to the proposal of 2011): the proceeds of withholding taxes charged on interest and royalty payments made by taxpayers will be shared according to the formula of that tax year. Withholding taxes charged on dividends will not be shared.

Preventing circumvention of tax exemptions (unchanged compared to the proposal of 2011): the tax exemption in favour of disposals of shares will be disallowed if this is illegitimately extended to sales of assets other than shares.

Formula for apportionment : one of the principal elements of the proposal is the formulary apportionment, comprised of three equally weighted factors (i.e. labour, assets and sales by destination). This combination reflects a balanced approach to distributing taxable profits amongst eligible Member States.

Administrative procedures : in contrast to the proposal of 2011, the common administrative rules are limited to the consolidated group.

Groups will deal with a single tax administration in the EU ('principal tax authority' or 'one-stop-shop'.) This will be based in the Member State where the parent company of the group ('principal taxpayer') is resident for tax purposes. Audits will be initiated and coordinated by the principal tax authority.

DELEGATED ACTS: the proposal contains provisions empowering the Commission to adopt delegated acts in accordance with Article 290 of the Treaty of the Functioning of the European Union.

Legislative proposal

Documents

Votes

A8-0051/2018 - Alain Lamassoure - Am 67=71 15/03/2018 12:16:54.000 #

2018/03/15 Outcome: -: 521, +: 119, 0: 12
GB NL IE MT CY DK LU LV EE FI PL SK HR SI LT EL BE SE CZ BG AT HU PT RO ES IT FR DE
Total
56
25
7
5
6
11
4
7
6
11
47
9
9
7
10
18
19
17
18
17
18
16
20
28
46
60
65
88
icon: ECR ECR
54

Netherlands ECR

2

Cyprus ECR

1

Finland ECR

For (1)

1

Slovakia ECR

1

Croatia ECR

For (1)

1

Lithuania ECR

1

Greece ECR

Against (1)

1

Czechia ECR

2

Bulgaria ECR

2

Romania ECR

Against (1)

1

Italy ECR

1
icon: EFDD EFDD
39

Poland EFDD

1

Lithuania EFDD

Against (1)

1

Sweden EFDD

2

Czechia EFDD

For (1)

1

Germany EFDD

For (1)

1
icon: NI NI
14

United Kingdom NI

For (1)

1

Denmark NI

Against (1)

1

Poland NI

1

Hungary NI

Abstain (1)

3

Romania NI

1

France NI

Against (1)

1

Germany NI

For (1)

1
icon: ENF ENF
33

United Kingdom ENF

For (1)

1

Poland ENF

1

Belgium ENF

For (1)

1

Germany ENF

For (1)

1
icon: GUE/NGL GUE/NGL
42

United Kingdom GUE/NGL

1

Netherlands GUE/NGL

2

Ireland GUE/NGL

Against (1)

3

Cyprus GUE/NGL

2

Denmark GUE/NGL

For (1)

1

Finland GUE/NGL

Against (1)

1

Sweden GUE/NGL

Against (1)

1

Czechia GUE/NGL

2

Italy GUE/NGL

2
icon: Verts/ALE Verts/ALE
46

United Kingdom Verts/ALE

3

Netherlands Verts/ALE

2

Luxembourg Verts/ALE

Against (1)

1

Latvia Verts/ALE

Against (1)

1

Estonia Verts/ALE

Against (1)

1

Finland Verts/ALE

Against (1)

1

Croatia Verts/ALE

Against (1)

1

Slovenia Verts/ALE

Against (1)

1

Lithuania Verts/ALE

Against (1)

1

Belgium Verts/ALE

2

Sweden Verts/ALE

3

Austria Verts/ALE

3

Hungary Verts/ALE

2

Italy Verts/ALE

Against (1)

1
icon: ALDE ALDE
64

United Kingdom ALDE

Against (1)

1

Denmark ALDE

3

Luxembourg ALDE

Against (1)

1

Latvia ALDE

1

Estonia ALDE

3

Croatia ALDE

Against (1)

1

Slovenia ALDE

Against (1)

1

Austria ALDE

Against (1)

1

Portugal ALDE

1

Romania ALDE

3
4
icon: S&D S&D
167

Netherlands S&D

3

Ireland S&D

For (1)

1

Malta S&D

2

Cyprus S&D

2

Denmark S&D

2

Latvia S&D

Against (1)

1

Estonia S&D

Against (1)

1

Finland S&D

2
3

Croatia S&D

2

Lithuania S&D

2

Czechia S&D

3

Hungary S&D

Against (1)

1
icon: PPE PPE
191

United Kingdom PPE

2

Ireland PPE

3

Malta PPE

Against (1)

3

Cyprus PPE

1

Denmark PPE

Against (1)

1

Luxembourg PPE

2

Estonia PPE

Against (1)

1

Finland PPE

2

Lithuania PPE

2

Belgium PPE

2

A8-0051/2018 - Alain Lamassoure - Am 4/2 15/03/2018 12:17:17.000 #

2018/03/15 Outcome: +: 477, -: 137, 0: 32
DE ES IT FR RO AT PT CZ EL BG HU BE LT HR SI PL SK FI EE LV LU NL DK SE MT IE CY GB
Total
87
46
60
64
28
18
20
18
18
17
16
19
9
9
7
47
9
11
6
7
4
24
11
16
5
7
6
55
icon: PPE PPE
189

Belgium PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Luxembourg PPE

2

Denmark PPE

Against (1)

1

Malta PPE

3

Ireland PPE

3

Cyprus PPE

Against (1)

1

United Kingdom PPE

Abstain (1)

1
icon: S&D S&D
164

Czechia S&D

3

Hungary S&D

For (1)

1

Croatia S&D

2

Estonia S&D

For (1)

1

Latvia S&D

1

Netherlands S&D

2

Denmark S&D

2

Sweden S&D

For (1)

4

Malta S&D

2

Ireland S&D

For (1)

1

Cyprus S&D

2
icon: ALDE ALDE
63

Romania ALDE

3

Austria ALDE

For (1)

1

Portugal ALDE

1

Lithuania ALDE

2

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Finland ALDE

Against (1)

Abstain (1)

4

Estonia ALDE

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Denmark ALDE

Against (1)

3

United Kingdom ALDE

1
icon: Verts/ALE Verts/ALE
46

Italy Verts/ALE

For (1)

1

Austria Verts/ALE

3

Hungary Verts/ALE

2

Belgium Verts/ALE

2

Lithuania Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Finland Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Latvia Verts/ALE

1

Luxembourg Verts/ALE

For (1)

1

Netherlands Verts/ALE

2

Sweden Verts/ALE

3

United Kingdom Verts/ALE

3
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

Against (1)

2

France GUE/NGL

3

Portugal GUE/NGL

Abstain (1)

4

Czechia GUE/NGL

2

Finland GUE/NGL

For (1)

1

Netherlands GUE/NGL

2

Denmark GUE/NGL

Against (1)

1

Sweden GUE/NGL

Against (1)

1

Ireland GUE/NGL

3

Cyprus GUE/NGL

2

United Kingdom GUE/NGL

Against (1)

1
icon: NI NI
14

Germany NI

For (1)

1

France NI

1

Romania NI

Against (1)

1
3

Poland NI

Against (1)

1

Denmark NI

1

United Kingdom NI

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Czechia EFDD

Against (1)

1

Lithuania EFDD

For (1)

1

Poland EFDD

1

Sweden EFDD

2
icon: ENF ENF
33

Germany ENF

Against (1)

1

Belgium ENF

Against (1)

1

Poland ENF

Against (1)

1

Netherlands ENF

4

United Kingdom ENF

Against (1)

1
icon: ECR ECR
54

Italy ECR

Against (1)

1

Romania ECR

For (1)

1

Czechia ECR

2

Greece ECR

For (1)

1

Bulgaria ECR

2

Lithuania ECR

Against (1)

1

Croatia ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Finland ECR

Against (1)

1

Netherlands ECR

2

Cyprus ECR

Against (1)

1

A8-0051/2018 - Alain Lamassoure - Am 5 15/03/2018 12:17:27.000 #

2018/03/15 Outcome: +: 472, -: 159, 0: 13
DE ES FR RO IT PT CZ AT HU BE EL PL LT FI HR SI SK EE NL LV LU DK BG SE IE MT CY GB
Total
86
45
64
28
60
20
17
18
16
19
17
46
10
11
9
7
9
6
25
7
5
11
16
17
7
5
6
55
icon: PPE PPE
187

Belgium PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Luxembourg PPE

Abstain (1)

3

Denmark PPE

Against (1)

1

Ireland PPE

3

Malta PPE

3

Cyprus PPE

Against (1)

1

United Kingdom PPE

Abstain (1)

1
icon: S&D S&D
166

Czechia S&D

3

Hungary S&D

For (1)

1

Croatia S&D

2

Estonia S&D

For (1)

1

Netherlands S&D

3

Latvia S&D

1

Denmark S&D

2

Sweden S&D

Against (1)

5

Ireland S&D

For (1)

1

Malta S&D

2

Cyprus S&D

2
icon: ALDE ALDE
64

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Estonia ALDE

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Denmark ALDE

Abstain (1)

3

United Kingdom ALDE

1
icon: Verts/ALE Verts/ALE
45

Italy Verts/ALE

For (1)

1

Austria Verts/ALE

3

Hungary Verts/ALE

2

Belgium Verts/ALE

2

Lithuania Verts/ALE

For (1)

1

Finland Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Netherlands Verts/ALE

2

Latvia Verts/ALE

1

Luxembourg Verts/ALE

For (1)

1

Sweden Verts/ALE

3

United Kingdom Verts/ALE

3
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

2

Czechia GUE/NGL

2

Finland GUE/NGL

For (1)

1

Netherlands GUE/NGL

For (1)

Against (1)

2

Denmark GUE/NGL

For (1)

1

Sweden GUE/NGL

For (1)

1

Ireland GUE/NGL

Against (2)

3

Cyprus GUE/NGL

2

United Kingdom GUE/NGL

Against (1)

1
icon: NI NI
14

Germany NI

For (1)

1

France NI

1

Romania NI

Against (1)

1
3

Poland NI

Against (1)

1

Denmark NI

1

United Kingdom NI

Against (1)

1
icon: ENF ENF
33

Germany ENF

Against (1)

1

Belgium ENF

Against (1)

1

Poland ENF

Abstain (1)

1

Netherlands ENF

4

United Kingdom ENF

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Czechia EFDD

Against (1)

1

Poland EFDD

1

Lithuania EFDD

For (1)

1

Sweden EFDD

2
icon: ECR ECR
52

Romania ECR

For (1)

1

Italy ECR

Against (1)

1

Czechia ECR

Against (1)

1

Greece ECR

For (1)

1

Lithuania ECR

Against (1)

1

Finland ECR

Against (1)

1

Croatia ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Netherlands ECR

2

Bulgaria ECR

2

Cyprus ECR

Against (1)

1

A8-0051/2018 - Alain Lamassoure - Am 22 15/03/2018 12:17:39.000 #

2018/03/15 Outcome: +: 464, -: 162, 0: 17
DE ES FR RO IT PT HU AT BE EL LT CZ PL FI HR SI SK EE NL LV SE LU DK BG IE CY MT GB
Total
87
42
65
27
61
20
14
17
19
18
10
18
47
11
9
7
9
6
25
7
17
4
11
16
7
6
5
56
icon: S&D S&D
166

Hungary S&D

For (1)

1

Czechia S&D

3

Croatia S&D

2

Estonia S&D

For (1)

1

Netherlands S&D

3

Latvia S&D

1

Denmark S&D

2

Ireland S&D

For (1)

1

Cyprus S&D

2

Malta S&D

2
icon: PPE PPE
189

Belgium PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Luxembourg PPE

For (1)

Against (1)

2

Denmark PPE

Against (1)

1

Ireland PPE

3

Cyprus PPE

Against (1)

1

United Kingdom PPE

2
icon: ALDE ALDE
64

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Estonia ALDE

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Denmark ALDE

Abstain (1)

3

United Kingdom ALDE

1
icon: Verts/ALE Verts/ALE
46

Italy Verts/ALE

For (1)

1

Hungary Verts/ALE

2

Austria Verts/ALE

3

Belgium Verts/ALE

2

Lithuania Verts/ALE

For (1)

1

Finland Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Netherlands Verts/ALE

2

Latvia Verts/ALE

1

Sweden Verts/ALE

3

Luxembourg Verts/ALE

For (1)

1

United Kingdom Verts/ALE

3
icon: GUE/NGL GUE/NGL
39

Italy GUE/NGL

2

Czechia GUE/NGL

2

Finland GUE/NGL

For (1)

1

Netherlands GUE/NGL

For (1)

Against (1)

2

Sweden GUE/NGL

For (1)

1

Denmark GUE/NGL

For (1)

1

Ireland GUE/NGL

Against (2)

3

Cyprus GUE/NGL

2

United Kingdom GUE/NGL

Against (1)

1
icon: NI NI
12

Germany NI

For (1)

1

France NI

1

Romania NI

Against (1)

1

Hungary NI

Against (1)

1

Poland NI

Against (1)

1

Denmark NI

1

United Kingdom NI

Against (1)

1
icon: ENF ENF
32

Germany ENF

Against (1)

1

Austria ENF

3

Belgium ENF

Against (1)

1

Poland ENF

Abstain (1)

1

Netherlands ENF

4

United Kingdom ENF

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Lithuania EFDD

For (1)

1

Czechia EFDD

Against (1)

1

Poland EFDD

1

Sweden EFDD

2
icon: ECR ECR
54

Romania ECR

For (1)

1

Italy ECR

Against (1)

1

Greece ECR

Against (1)

1

Lithuania ECR

Against (1)

1

Czechia ECR

2

Finland ECR

Against (1)

1

Croatia ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Netherlands ECR

2

Bulgaria ECR

2

Cyprus ECR

Against (1)

1

A8-0051/2018 - Alain Lamassoure - Am 31 15/03/2018 12:17:50.000 #

2018/03/15 Outcome: +: 520, -: 101, 0: 24
DE FR IT ES RO PT HU AT EL NL BG BE FI LT CZ HR SI PL SK EE LV DK LU SE IE CY MT GB
Total
87
64
61
46
28
20
16
18
17
25
17
18
11
10
18
9
7
45
9
6
7
11
3
17
7
6
4
56
icon: PPE PPE
188

Belgium PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Denmark PPE

For (1)

1

Luxembourg PPE

For (1)

1

Ireland PPE

3

Cyprus PPE

Against (1)

1

United Kingdom PPE

2
icon: S&D S&D
167

Hungary S&D

For (1)

1

Netherlands S&D

3

Czechia S&D

3

Croatia S&D

2

Estonia S&D

For (1)

1

Latvia S&D

1

Denmark S&D

2

Ireland S&D

For (1)

1

Cyprus S&D

2

Malta S&D

Against (1)

1
icon: ALDE ALDE
63

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Estonia ALDE

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Sweden ALDE

Against (1)

3

United Kingdom ALDE

1
icon: Verts/ALE Verts/ALE
45

Italy Verts/ALE

For (1)

1

Hungary Verts/ALE

2

Austria Verts/ALE

3

Netherlands Verts/ALE

2

Belgium Verts/ALE

2

Finland Verts/ALE

For (1)

1

Lithuania Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Latvia Verts/ALE

1

Luxembourg Verts/ALE

For (1)

1

Sweden Verts/ALE

3

United Kingdom Verts/ALE

3
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

2

Netherlands GUE/NGL

2

Finland GUE/NGL

For (1)

1

Czechia GUE/NGL

2

Denmark GUE/NGL

For (1)

1

Sweden GUE/NGL

For (1)

1

Ireland GUE/NGL

3

Cyprus GUE/NGL

2

United Kingdom GUE/NGL

1
icon: ENF ENF
32

Germany ENF

Against (1)

1

Netherlands ENF

4

Poland ENF

Against (1)

1

United Kingdom ENF

Against (1)

1
icon: NI NI
14

Germany NI

For (1)

1

France NI

1

Romania NI

Against (1)

1

Poland NI

Against (1)

1

Denmark NI

1

United Kingdom NI

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Lithuania EFDD

For (1)

1

Czechia EFDD

Against (1)

1

Poland EFDD

1

Sweden EFDD

2
icon: ECR ECR
53

Italy ECR

Against (1)

1

Romania ECR

For (1)

1

Greece ECR

Abstain (1)

1

Netherlands ECR

2

Bulgaria ECR

2

Finland ECR

Against (1)

1

Lithuania ECR

Against (1)

1

Czechia ECR

2

Croatia ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Cyprus ECR

Against (1)

1

A8-0051/2018 - Alain Lamassoure - Am 62 15/03/2018 12:18:00.000 #

2018/03/15 Outcome: +: 456, -: 163, 0: 26
DE IT ES RO FR PT BE CZ HU EL PL LT FI AT SK NL HR SI EE DK MT LV CY BG LU IE SE GB
Total
88
60
46
27
65
19
19
18
15
18
47
10
11
18
8
25
9
7
6
11
4
7
5
17
3
7
17
56
icon: PPE PPE
188

Belgium PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Denmark PPE

Abstain (1)

1

Cyprus PPE

1

Luxembourg PPE

For (1)

1

Ireland PPE

3

United Kingdom PPE

2
icon: S&D S&D
164

Czechia S&D

3

Hungary S&D

For (1)

1

Netherlands S&D

3

Croatia S&D

2

Estonia S&D

For (1)

1

Denmark S&D

2

Malta S&D

For (1)

1

Latvia S&D

1

Cyprus S&D

For (1)

1

Ireland S&D

For (1)

1
icon: ALDE ALDE
64

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Estonia ALDE

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Sweden ALDE

Against (1)

3

United Kingdom ALDE

1
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

2

Portugal GUE/NGL

For (1)

4

Czechia GUE/NGL

2

Finland GUE/NGL

Abstain (1)

1

Netherlands GUE/NGL

2

Denmark GUE/NGL

For (1)

1

Cyprus GUE/NGL

2

Ireland GUE/NGL

3

Sweden GUE/NGL

Against (1)

1

United Kingdom GUE/NGL

1
icon: NI NI
13

Germany NI

Against (1)

1

Romania NI

Against (1)

1

France NI

1

Hungary NI

2

Poland NI

Against (1)

1

Denmark NI

1

United Kingdom NI

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Czechia EFDD

Against (1)

1

Poland EFDD

1

Lithuania EFDD

For (1)

1

Sweden EFDD

2
icon: ENF ENF
33

Germany ENF

Against (1)

1

Belgium ENF

For (1)

1

Poland ENF

Abstain (1)

1

Netherlands ENF

4

United Kingdom ENF

Against (1)

1
icon: ECR ECR
54

Germany ECR

For (1)

4

Italy ECR

Against (1)

1

Romania ECR

For (1)

1

Czechia ECR

2

Greece ECR

For (1)

1

Lithuania ECR

Against (1)

1

Finland ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Netherlands ECR

2

Croatia ECR

Against (1)

1

Cyprus ECR

Against (1)

1

Bulgaria ECR

2
icon: Verts/ALE Verts/ALE
46

Italy Verts/ALE

Against (1)

1

Belgium Verts/ALE

2

Hungary Verts/ALE

2

Lithuania Verts/ALE

Against (1)

1

Finland Verts/ALE

Against (1)

1

Austria Verts/ALE

For (1)

Against (2)

3

Netherlands Verts/ALE

2

Croatia Verts/ALE

Against (1)

1

Slovenia Verts/ALE

Against (1)

1

Estonia Verts/ALE

Against (1)

1

Latvia Verts/ALE

Against (1)

1

Luxembourg Verts/ALE

Against (1)

1

Sweden Verts/ALE

3

United Kingdom Verts/ALE

3

A8-0051/2018 - Alain Lamassoure - Am 63 15/03/2018 12:18:10.000 #

2018/03/15 Outcome: +: 451, -: 184, 0: 8
DE IT ES RO FR PT CZ AT HU BE LT PL HR EL SK EE SI LV FI NL LU BG CY DK IE MT GB SE
Total
83
60
46
28
65
20
18
18
16
19
10
46
9
18
9
6
6
7
10
25
3
17
6
11
7
5
56
17
icon: PPE PPE
187

Belgium PPE

2

Estonia PPE

For (1)

1

Finland PPE

2

Luxembourg PPE

For (1)

1

Cyprus PPE

1

Denmark PPE

Against (1)

1

Ireland PPE

3

United Kingdom PPE

2
icon: S&D S&D
165

Czechia S&D

3

Hungary S&D

For (1)

1

Croatia S&D

2

Estonia S&D

For (1)

1

Latvia S&D

1

Netherlands S&D

3

Cyprus S&D

2

Denmark S&D

2

Ireland S&D

For (1)

1

Malta S&D

2
icon: ALDE ALDE
64

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Estonia ALDE

3

Slovenia ALDE

For (1)

1

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Denmark ALDE

Against (1)

3

United Kingdom ALDE

1

Sweden ALDE

Against (1)

3
icon: Verts/ALE Verts/ALE
44

Italy Verts/ALE

For (1)

1

Austria Verts/ALE

3

Hungary Verts/ALE

2

Belgium Verts/ALE

2

Lithuania Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Latvia Verts/ALE

1

Netherlands Verts/ALE

2

Luxembourg Verts/ALE

For (1)

1

United Kingdom Verts/ALE

3

Sweden Verts/ALE

3
icon: NI NI
13

Germany NI

For (1)

1

Romania NI

Against (1)

1

France NI

1
3

Denmark NI

1

United Kingdom NI

Abstain (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Czechia EFDD

Against (1)

1

Lithuania EFDD

For (1)

1

Poland EFDD

1

Sweden EFDD

2
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

2

Portugal GUE/NGL

For (1)

4

Czechia GUE/NGL

2

Finland GUE/NGL

Abstain (1)

1

Netherlands GUE/NGL

2

Cyprus GUE/NGL

2

Denmark GUE/NGL

Against (1)

1

Ireland GUE/NGL

Against (2)

3

United Kingdom GUE/NGL

Against (1)

1

Sweden GUE/NGL

Against (1)

1
icon: ENF ENF
33

Germany ENF

Against (1)

1

Belgium ENF

Against (1)

1

Poland ENF

Against (1)

1

Netherlands ENF

4

United Kingdom ENF

Against (1)

1
icon: ECR ECR
54

Italy ECR

Against (1)

1

Romania ECR

For (1)

1

Czechia ECR

2

Lithuania ECR

Against (1)

1

Croatia ECR

Against (1)

1

Greece ECR

For (1)

1

Slovakia ECR

Against (1)

1

Finland ECR

Against (1)

1

Netherlands ECR

2

Bulgaria ECR

2

Cyprus ECR

Against (1)

1

A8-0051/2018 - Alain Lamassoure - Am 66 15/03/2018 12:18:20.000 #

2018/03/15 Outcome: -: 501, +: 109, 0: 35
EL LU EE CY IE LV SI MT SK SE ES HU HR FI LT DK AT PT BE BG CZ NL IT RO DE GB FR PL
Total
18
3
6
6
7
7
7
5
8
17
45
16
9
10
10
11
17
20
19
17
18
25
61
27
86
56
65
47
icon: Verts/ALE Verts/ALE
44

Luxembourg Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Latvia Verts/ALE

1

Slovenia Verts/ALE

For (1)

1

Sweden Verts/ALE

3

Hungary Verts/ALE

2

Croatia Verts/ALE

For (1)

1

Lithuania Verts/ALE

For (1)

1

Austria Verts/ALE

3

Belgium Verts/ALE

2

Netherlands Verts/ALE

2

Italy Verts/ALE

For (1)

1

United Kingdom Verts/ALE

3
icon: GUE/NGL GUE/NGL
42

Cyprus GUE/NGL

2

Ireland GUE/NGL

Against (2)

3

Sweden GUE/NGL

Against (1)

1

Finland GUE/NGL

For (1)

1

Denmark GUE/NGL

For (1)

1

Czechia GUE/NGL

2

Netherlands GUE/NGL

For (1)

Against (1)

2

Italy GUE/NGL

2

United Kingdom GUE/NGL

Against (1)

1
icon: NI NI
14

Hungary NI

Abstain (1)

3

Denmark NI

Against (1)

1

Romania NI

Against (1)

1

Germany NI

For (1)

1

United Kingdom NI

For (1)

1

France NI

Against (1)

1

Poland NI

Against (1)

1
icon: EFDD EFDD
39

Sweden EFDD

2

Lithuania EFDD

Against (1)

1

Czechia EFDD

Against (1)

1

Germany EFDD

Against (1)

1

Poland EFDD

1
icon: ENF ENF
33

Belgium ENF

Against (1)

1

Netherlands ENF

4

Germany ENF

Against (1)

1

United Kingdom ENF

Against (1)

1

Poland ENF

Against (1)

1
icon: ECR ECR
54

Greece ECR

For (1)

1

Cyprus ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Croatia ECR

Against (1)

1

Finland ECR

Against (1)

1

Lithuania ECR

Against (1)

1

Bulgaria ECR

2

Czechia ECR

2

Netherlands ECR

2

Italy ECR

Against (1)

1

Romania ECR

Against (1)

1
icon: ALDE ALDE
64

Luxembourg ALDE

Against (1)

1

Estonia ALDE

3

Latvia ALDE

1

Slovenia ALDE

Against (1)

1

Croatia ALDE

Against (1)

1

Denmark ALDE

3

Austria ALDE

Against (1)

1

Portugal ALDE

1

Romania ALDE

For (1)

3

Germany ALDE

Against (1)

Abstain (1)

4

United Kingdom ALDE

Against (1)

1
icon: S&D S&D
166

Estonia S&D

Against (1)

1

Cyprus S&D

2

Ireland S&D

Against (1)

1

Latvia S&D

Against (1)

1

Malta S&D

2
3

Hungary S&D

Against (1)

1

Croatia S&D

2

Finland S&D

2

Lithuania S&D

2

Denmark S&D

2

Czechia S&D

3

Netherlands S&D

3
icon: PPE PPE
187

Luxembourg PPE

Against (1)

1

Estonia PPE

Against (1)

1

Cyprus PPE

Against (1)

1

Ireland PPE

3

Slovakia PPE

4

Finland PPE

2

Lithuania PPE

2

Denmark PPE

Against (1)

1

Belgium PPE

2

United Kingdom PPE

2

A8-0051/2018 - Alain Lamassoure - Proposition de la Commission 15/03/2018 12:19:01.000 #

2018/03/15 Outcome: +: 438, -: 145, 0: 69
DE IT FR ES RO PT BG HU AT BE LT CZ FI HR SI SK EE EL LV LU DK NL SE CY PL IE MT GB
Total
88
61
65
46
28
20
17
16
18
19
10
18
11
9
7
9
6
18
7
4
11
25
15
6
47
7
6
56
icon: S&D S&D
167

Hungary S&D

For (1)

1

Czechia S&D

3

Croatia S&D

2

Estonia S&D

For (1)

1

Latvia S&D

1

Denmark S&D

2

Netherlands S&D

3

Sweden S&D

Against (1)

3

Cyprus S&D

Against (1)

2

Ireland S&D

For (1)

1

Malta S&D

3
icon: PPE PPE
191

Belgium PPE

2

Lithuania PPE

2

Finland PPE

2

Estonia PPE

For (1)

1

Luxembourg PPE

For (1)

Against (1)

2

Denmark PPE

Against (1)

1

Cyprus PPE

Against (1)

1

Ireland PPE

3

United Kingdom PPE

Against (1)

Abstain (1)

2
icon: ALDE ALDE
64

Romania ALDE

3

Portugal ALDE

1

Austria ALDE

For (1)

1

Croatia ALDE

For (1)

1

Slovenia ALDE

For (1)

1

Estonia ALDE

Abstain (1)

3

Latvia ALDE

1

Luxembourg ALDE

For (1)

1

Denmark ALDE

Abstain (1)

3

Sweden ALDE

Against (1)

3

United Kingdom ALDE

1
icon: Verts/ALE Verts/ALE
46

Italy Verts/ALE

For (1)

1

Hungary Verts/ALE

2

Austria Verts/ALE

3

Belgium Verts/ALE

2

Lithuania Verts/ALE

For (1)

1

Finland Verts/ALE

For (1)

1

Croatia Verts/ALE

For (1)

1

Slovenia Verts/ALE

For (1)

1

Estonia Verts/ALE

For (1)

1

Latvia Verts/ALE

1

Luxembourg Verts/ALE

For (1)

1

Netherlands Verts/ALE

2

Sweden Verts/ALE

3

United Kingdom Verts/ALE

3
icon: NI NI
14

Germany NI

Against (1)

1

France NI

1

Romania NI

Against (1)

1
3

Denmark NI

1

Poland NI

Against (1)

1

United Kingdom NI

Against (1)

1
icon: EFDD EFDD
39

Germany EFDD

Against (1)

1

Lithuania EFDD

For (1)

1

Czechia EFDD

Against (1)

1

Sweden EFDD

2

Poland EFDD

1
icon: GUE/NGL GUE/NGL
42

Italy GUE/NGL

2

France GUE/NGL

3

Portugal GUE/NGL

Abstain (1)

4

Czechia GUE/NGL

2

Finland GUE/NGL

For (1)

1

Denmark GUE/NGL

Against (1)

1

Netherlands GUE/NGL

2

Sweden GUE/NGL

Against (1)

1

Cyprus GUE/NGL

2

Ireland GUE/NGL

3

United Kingdom GUE/NGL

Against (1)

1
icon: ENF ENF
33

Germany ENF

Against (1)

1

Belgium ENF

Against (1)

1

Netherlands ENF

4

Poland ENF

Against (1)

1

United Kingdom ENF

Against (1)

1
icon: ECR ECR
54

Italy ECR

Against (1)

1

Romania ECR

For (1)

1

Bulgaria ECR

2

Lithuania ECR

Against (1)

1

Czechia ECR

2

Finland ECR

Against (1)

1

Croatia ECR

Against (1)

1

Slovakia ECR

Against (1)

1

Greece ECR

Abstain (1)

1

Netherlands ECR

2

Cyprus ECR

Against (1)

1
AmendmentsDossier
301 2016/0336(CNS)
2017/05/15 JURI 30 amendments...
source: 604.719
2017/09/29 ECON 271 amendments...
source: 609.575

History

(these mark the time of scraping, not the official date of the change)

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  • date: 2017-02-08T00:00:00 docs: url: http://www.europarl.europa.eu/RegData/docs_autres_institutions/parlements_nationaux/com/2016/0683/IE_SENATE_AVIS-COM(2016)0683_EN.pdf title: PE599.678 type: Reasoned opinion body: IE_SENATE
  • date: 2017-02-23T00:00:00 docs: url: http://www.europarl.europa.eu/RegData/docs_autres_institutions/parlements_nationaux/com/2016/0683/SE_PARLIAMENT_AVIS-COM(2016)0683_EN.pdf title: PE599.834 type: Reasoned opinion body: SE_PARLIAMENT
  • date: 2017-07-13T00:00:00 docs: url: http://www.europarl.europa.eu/sides/getDoc.do?type=COMPARL&mode=XML&language=EN&reference=PE608.035 title: PE608.035 type: Committee draft report body: EP
  • date: 2017-09-29T00:00:00 docs: url: http://www.europarl.europa.eu/sides/getDoc.do?type=COMPARL&mode=XML&language=EN&reference=PE609.575 title: PE609.575 type: Amendments tabled in committee body: EP
  • date: 2017-10-04T00:00:00 docs: url: http://www.europarl.europa.eu/sides/getDoc.do?type=COMPARL&mode=XML&language=EN&reference=PE602.928&secondRef=04 title: PE602.928 committee: JURI type: Committee opinion body: EP
  • date: 2018-05-24T00:00:00 docs: url: /oeil/spdoc.do?i=30814&j=0&l=en title: SP(2018)242 type: Commission response to text adopted in plenary
  • date: 2016-12-22T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: DE_BUNDESRAT
  • date: 2016-12-21T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: ES_PARLIAMENT
  • date: 2016-12-22T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: PT_PARLIAMENT
  • date: 2017-01-24T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: AT_BUNDESRAT
  • date: 2017-01-17T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: UK_HOUSE-OF-COMMONS
  • date: 2017-04-04T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: CY_PARLIAMENT
  • date: 2017-03-14T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: CZ_SENATE
  • date: 2017-05-31T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: RO_CHAMBER
  • date: 2019-01-11T00:00:00 docs: url: http://www.connefof.europarl.europa.eu/connefof/app/exp/COM(2016)0683 title: COM(2016)0683 type: Contribution body: FR_ASSEMBLY
events
  • date: 2016-10-25T00:00:00 type: Legislative proposal published body: EC docs: url: http://www.europarl.europa.eu/RegData/docs_autres_institutions/commission_europeenne/com/2016/0683/COM_COM(2016)0683(ANN)_EN.pdf title: COM(2016)0683 url: https://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=EN&type_doc=COMfinal&an_doc=2016&nu_doc=0683 title: EUR-Lex summary: PURPOSE: to present a proposal for a re-launched Common Consolidated Corporate Tax Base (CCCTB) to ensure a corporate tax system that encourages growth and fairness in the internal market. PROPOSED ACT: Council Directive. ROLE OF THE EUROPEAN PARLIAMENT: the Council adopts the act after consulting Parliament but without being obliged to follow the latter’s opinion. BACKGROUND: currently, businesses with cross-border activity have to comply with up to 28 divergent corporate tax systems. Generally, corporate income is taxed at national level, but the economic environment has become more globalised, mobile and digital. Business models and corporate structures are more complex, making it easier to shift profits. In March 2011, the Commission proposed a directive for a Common Consolidated Corporate Tax Base (CCCTB). The proposal, which is still pending in Council, aims to provide companies with a single set of corporate tax rules for doing business across the internal market, thereby facilitating their cross-border activity. The discussions in Council since 2011 have shown that the CCCTB proposal is unlikely to get adopted, in its entirety, without a staged approach. The Commission, in its action plan of June 2015, advocated a step-by-step approach to the CCCTB . Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, the Commission considers it necessary to divide the ambitious CCCTB initiative into two separate proposals. It proposes, at a first stage, rules on a common corporate tax base , before addressing, at a second stage, the issue of consolidation. This proposal for a Directive focuses on the so-called 'second step' of the staged approach (consolidation) , i.e. after the elements of the common base have politically been agreed. Until this is achieved, the 2011 proposal for a CCCTB will remain pending for examination in Council. The Commission will submit the two proposals, i.e. for a common corporate tax base and a CCCTB, simultaneously and as part of a single initiative. The proposal of 2011 will be withdrawn at the same time as the Commission adopts the new proposals. This initiative on re-launching the CCCTB features prominently in the Commission’s larger project in the field of fairer taxation. It will be presented at the same time as the proposal for a directive on hybrid mismatches involving third countries (which will amend the Directive tax avoidance) and a directive on dispute settlement. IMPACT ASSESSMENT: the main policy option that has been considered is a proposal for a common consolidated corporate tax base. A key choice to be made relates to the scope of such a tax base, i.e. to whom it would apply. Assessing the different options has led to a preferred option: a CCCTB mandatory for large companies, equipped with an 'Allowance for Growth and Investment' and with an allowance for research and development expenses. The anticipated economic benefits of the proposal are positive, leading to an increase in investment and employment of up to 3.4% and 0.6%, respectively. Overall, growth would increase by up to 1.2%. CONTENT: the proposal is the 'second step' in a staged approach towards an EU-wide corporate tax system with cross-border consolidation of the tax results amongst members of the same group. Scope: in contrast to the proposal of 2011, which laid down an optional system for all, this proposal will be mandatory for groups of companies beyond a certain size (whose consolidated turnover is above EUR 750 million). The threshold is in line with the approach taken in other EU initiatives to counter tax avoidance. At the same time, the common rules will be available, as an option, to a wide scope of groups that fall short of the size threshold. This allows SMEs and micro-enterprises the opportunity to benefit from the advantages of a CCCTB without making it compulsory for this set of companies. Definition of group: (unchanged compared to the proposal of 2011): eligibility for the consolidated tax group will be determined in accordance with a two-part test based on (i) control (more than 50% of voting rights) and (ii) ownership (more than 75 % of equity) or rights to profits (more than 75 % of rights giving entitlement to profit). These thresholds must be met throughout the tax year; otherwise, the failing company will have to leave the group immediately. Business reorganisations and taxation of losses and unrealised capital gains : the proposed framework chiefly involves the treatment of losses and unrealised capital gains on entering and leaving the group. There are rules to deal with unrealised capital gains which have accrued to fixed assets where the assets are disposed of within a short period after their entry into, or exit from, a group. A Member State (in the case of an entry into a group) or the group (in the case of an exit from a group) are given the right to tax underlying capital gains to the extent those were created in their tax jurisdiction. Moreover, the tax treatment of capital gains engrained in self-generated intangible assets calls for a customised approach, which will involve assessing them on the basis of a suitable proxy, that is to say, research and development , and marketing and advertising costs over a specified period. Withholding taxes (unchanged compared to the proposal of 2011): the proceeds of withholding taxes charged on interest and royalty payments made by taxpayers will be shared according to the formula of that tax year. Withholding taxes charged on dividends will not be shared. Preventing circumvention of tax exemptions (unchanged compared to the proposal of 2011): the tax exemption in favour of disposals of shares will be disallowed if this is illegitimately extended to sales of assets other than shares. Formula for apportionment : one of the principal elements of the proposal is the formulary apportionment, comprised of three equally weighted factors (i.e. labour, assets and sales by destination). This combination reflects a balanced approach to distributing taxable profits amongst eligible Member States. Administrative procedures : in contrast to the proposal of 2011, the common administrative rules are limited to the consolidated group. Groups will deal with a single tax administration in the EU ('principal tax authority' or 'one-stop-shop'.) This will be based in the Member State where the parent company of the group ('principal taxpayer') is resident for tax purposes. Audits will be initiated and coordinated by the principal tax authority. DELEGATED ACTS: the proposal contains provisions empowering the Commission to adopt delegated acts in accordance with Article 290 of the Treaty of the Functioning of the European Union.
  • date: 2016-11-24T00:00:00 type: Committee referral announced in Parliament, 1st reading/single reading body: EP
  • date: 2016-12-06T00:00:00 type: Debate in Council body: CSL docs: url: http://register.consilium.europa.eu/content/out?lang=EN&typ=SET&i=SMPL&ROWSPP=25&RESULTSET=1&NRROWS=500&DOC_LANCD=EN&ORDERBY=DOC_DATE+DESC&CONTENTS=3506*&MEET_DATE=06/12/2016 title: 3506
  • date: 2018-02-21T00:00:00 type: Vote in committee, 1st reading/single reading body: EP
  • date: 2018-03-01T00:00:00 type: Committee report tabled for plenary, 1st reading/single reading body: EP docs: url: http://www.europarl.europa.eu/sides/getDoc.do?type=REPORT&mode=XML&reference=A8-2018-0051&language=EN title: A8-0051/2018 summary: The Committee on Economic and Monetary Affairs adopted, following Parliament’s consultation , the report by Alain LAMASSOURE (EPP, FR) on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB). The committee recommended that the European Parliament approve the Commission proposal subject to the following amendments: The report noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models. Subject matter : Members are calling for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system. Once implemented in all Member States, a CCCTB would ensure that taxes are paid the internal market. Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning. Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, it is very important to ensure simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base . Because such a change of regime is a significant step in the completion of the internal market, it needs flexibility in order to be properly executed from the outset. Hence, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States . Scope : the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years. Tax residence : the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity , whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment , in a Member State. Effect of consolidation : the tax basis of a consolidated group shall be determined as if it were one single entity . For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group. Apportionment of the common consolidated tax base : in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities. Informing the European Parliament : the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council. Compensation mechanism : in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a dedicated compensation mechanism , operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years. Implementation report and review : the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.
  • date: 2018-03-14T00:00:00 type: Debate in Parliament body: EP docs: url: http://www.europarl.europa.eu/sides/getDoc.do?secondRef=TOC&language=EN&reference=20180314&type=CRE title: Debate in Parliament
  • date: 2018-03-15T00:00:00 type: Results of vote in Parliament body: EP docs: url: https://oeil.secure.europarl.europa.eu/oeil/popups/sda.do?id=30814&l=en title: Results of vote in Parliament
  • date: 2018-03-15T00:00:00 type: Decision by Parliament, 1st reading/single reading body: EP docs: url: http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P8-TA-2018-0087 title: T8-0087/2018 summary: The European Parliament adopted by 438 votes to 145, with 69 abstentions, following Parliament’s consultation, a legislative resolution on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB). Parliament approved the Commission proposal subject to the following amendments: Members noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models. Subject matter : Parliament called for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system. Once implemented in all Member States, a CCCTB would ensure that taxes are paid where profits are generated and where companies have permanent establishment . Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning. The amended text stressed the importance of ensuring the simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base. Moreover, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States . If the Council fails to adopt a unanimous decision on the proposal to establish a CCCTB, the Commission should issue a new proposal in accordance with the ordinary legislative procedure. As a last resort, an enhanced cooperation should be initiated by Member States. Scope : the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years . Digital presence in a country to determine taxable profits : the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity , whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment , in a Member State. Effect of consolidation : the tax basis of a consolidated group shall be determined as if it were one single entity . For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group. Where the consolidated tax base is negative, the loss shall be carried forward and be set off against the next positive consolidated tax base for a maximum period of five years. Apportionment of the common consolidated tax base : in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities. The volume of personal data collected pursuant to the data factor shall be measured at the end of the tax year in each Member State. Informing the European Parliament : the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council. Compensation mechanism : in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a temporary compensation mechanism, operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years. Informing the European Parliament : Members suggested that the European Parliament organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council. Implementation report and review : the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.
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  • body: EC dg: url: http://ec.europa.eu/info/departments/taxation-and-customs-union_en title: Taxation and Customs Union commissioner: MOSCOVICI Pierre
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  • See also
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  • url: http://register.consilium.europa.eu/content/out?lang=EN&typ=SET&i=SMPL&ROWSPP=25&RESULTSET=1&NRROWS=500&DOC_LANCD=EN&ORDERBY=DOC_DATE+DESC&CONTENTS=3506*&MEET_DATE=06/12/2016 type: Debate in Council title: 3506
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  • The European Parliament adopted by 438 votes to 145, with 69 abstentions, following Parliament’s consultation, a legislative resolution on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB).

    Parliament approved the Commission proposal subject to the following amendments:

    Members noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models.

    Subject matter: Parliament called for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system.

    Once implemented in all Member States, a CCCTB would ensure that taxes are paid where profits are generated and where companies have permanent establishment. Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning.

    The amended text stressed the importance of ensuring the simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base. Moreover, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States. If the Council fails to adopt a unanimous decision on the proposal to establish a CCCTB, the Commission should issue a new proposal in accordance with the ordinary legislative procedure. As a last resort, an enhanced cooperation should be initiated by Member States.

    Scope: the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years.

    Digital presence in a country to determine taxable profits: the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity, whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment, in a Member State.

    Effect of consolidation: the tax basis of a consolidated group shall be determined as if it were one single entity. For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group.

    Where the consolidated tax base is negative, the loss shall be carried forward and be set off against the next positive consolidated tax base for a maximum period of five years.

    Apportionment of the common consolidated tax base: in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities.

    The volume of personal data collected pursuant to the data factor shall be measured at the end of the tax year in each Member State.

    Informing the European Parliament: the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

    Compensation mechanism: in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a temporary compensation mechanism, operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years.

    Informing the European Parliament: Members suggested that the European Parliament organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

    Implementation report and review: the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.

activities/5/docs
  • url: http://www.europarl.europa.eu/sides/getDoc.do?secondRef=TOC&language=EN&reference=20180314&type=CRE type: Debate in Parliament title: Debate in Parliament
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  • url: http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P8-TA-2018-0087 type: Decision by Parliament, 1st reading/single reading title: T8-0087/2018
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  • The Committee on Economic and Monetary Affairs adopted, following Parliament’s consultation, the report by Alain LAMASSOURE (EPP, FR) on the proposal for a Council directive on a Common Consolidated Corporate Tax Base (CCCTB).

    The committee recommended that the European Parliament approve the Commission proposal subject to the following amendments:

    The report noted that in times of globalisation and digitalisation, taxation of in particular financial and intellectual capital on a source base is becoming increasingly harder to retrace and easier to manipulate. The mainstream digitalisation of many sectors of the economy coupled with the fast developing digital economy calls into question the suitability of the Union corporate tax models.

    Subject matter: Members are calling for a Directive which aims to establish a common base for the taxation in the Union of certain companies and lays down rules for the calculation of that base, including rules on measures to prevent tax avoidance and on measures relating to the international dimension of the proposed tax system.

    Once implemented in all Member States, a CCCTB would ensure that taxes are paid the internal market. Such an approach would best serve the aim of eradicating distortions in the functioning of the internal market and act as a powerful to tackle aggressive tax planning.

    Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, it is very important to ensure simultaneous entry into force of the Directive on a Common Corporate Tax Base and the Directive on a Common Consolidated Corporate Tax Base. Because such a change of regime is a significant step in the completion of the internal market, it needs flexibility in order to be properly executed from the outset. Hence, as the internal market encompasses all Member States, the CCCTB should be introduced in all Member States.

    Scope: the rules of this Directive shall apply to a company that is established under the laws of a Member State, including its permanent and digital permanent establishments in other Member States, where the company meets specific conditions, in particular, that they belong to a consolidated group for financial accounting purposes with a total consolidated group revenue that exceeded EUR 750 million during the financial year preceding the relevant financial year. That threshold shall be lowered to zero over a maximum period of seven years.

    Tax residence: the amended text stipulated that a resident taxpayer shall be subject to corporate tax on all income generated by any activity, whether inside or outside the Member State where it is resident for tax purposes. A non-resident taxpayer shall be subject to corporate tax on all income from an activity carried on through a permanent establishment, including through a digital permanent establishment, in a Member State.

    Effect of consolidation: the tax basis of a consolidated group shall be determined as if it were one single entity. For that purpose, the aggregate tax basis of the group shall be retreated in order to eliminate all profits or losses including those arising from any transaction, whatever its nature, between two or more entities within the group.

    Apportionment of the common consolidated tax base: in its proposal, the Commission suggested that taxable profits be shared between the different Member States where the company operates. The apportionment formula comprises of three equally weighted factors: sales, assets and labour. Members proposed adding the fourth factor - personal data collection and exploitation for commercial purposes (data) to ensure that CCCTB also applies to digital activities.

    Informing the European Parliament: the European Parliament shall organise an interparliamentary conference to evaluate the CCCTB regime, taking into account the outcomes of the tax policy discussions held under the procedure of the European Semester. It shall communicate its opinion and conclusions thereon by means of a resolution addressed to the Commission and the Council.

    Compensation mechanism: in order to compensate for sudden shocks in tax revenues across Member States arising from fiscal gains and losses directly and solely caused by the switch to the new regime introduced by this proposed Directive, the Commission shall establish a dedicated compensation mechanism, operational from the entry into force of this Directive. Compensation shall be adjusted each year to take into account national or regional decisions taken prior to the entry into force of this Directive. The compensation mechanism shall be financed by the fiscal surplus from those Member States that experience gains in fiscal revenues, and shall be set for an initial period of seven years.

    Implementation report and review: the Commission shall, five years after the entry into force of this Directive, assess its application and report to the European Parliament and the Council on the operation of this Directive. The Commission shall propose the terms and conditions to allocate a part of the fiscal revenues generated from the common consolidated corporate tax base to the budget of the Union in order to proportionally reduce Member States contributions to the same budget.

activities/4
date
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  • PURPOSE: to present a proposal for a re-launched Common Consolidated Corporate Tax Base (CCCTB) to ensure a corporate tax system that encourages growth and fairness in the internal market.

    PROPOSED ACT: Council Directive.

    ROLE OF THE EUROPEAN PARLIAMENT: the Council adopts the act after consulting Parliament but without being obliged to follow the latter’s opinion.

    BACKGROUND: currently, businesses with cross-border activity have to comply with up to 28 divergent corporate tax systems. Generally, corporate income is taxed at national level, but the economic environment has become more globalised, mobile and digital. Business models and corporate structures are more complex, making it easier to shift profits.

    In March 2011, the Commission proposed a directive for a Common Consolidated Corporate Tax Base (CCCTB). The proposal, which is still pending in Council, aims to provide companies with a single set of corporate tax rules for doing business across the internal market, thereby facilitating their cross-border activity.

    The discussions in Council since 2011 have shown that the CCCTB proposal is unlikely to get adopted, in its entirety, without a staged approach. The Commission, in its action plan of June 2015, advocated a step-by-step approach to the CCCTB.

    Considering the need to act swiftly in order to ensure a proper functioning of the internal market by making it, on the one hand, friendlier to trade and investment and, on the other hand, more resilient to tax avoidance schemes, the Commission considers it necessary to divide the ambitious CCCTB initiative into two separate proposals. It proposes, at a first stage, rules on a common corporate tax base, before addressing, at a second stage, the issue of consolidation.

    This proposal for a Directive focuses on the so-called 'second step' of the staged approach (consolidation), i.e. after the elements of the common base have politically been agreed. Until this is achieved, the 2011 proposal for a CCCTB will remain pending for examination in Council.  The Commission will submit the two proposals, i.e. for a common corporate tax base and a CCCTB, simultaneously and as part of a single initiative. The proposal of 2011 will be withdrawn at the same time as the Commission adopts the new proposals.

    This initiative on re-launching the CCCTB features prominently in the Commission’s larger project in the field of fairer taxation. It will be presented at the same time as the proposal for a directive on hybrid mismatches involving third countries (which will amend the Directive tax avoidance) and a directive on dispute settlement. 

    IMPACT ASSESSMENT: the main policy option that has been considered is a proposal for a common consolidated corporate tax base. A key choice to be made relates to the scope of such a tax base, i.e. to whom it would apply.

    Assessing the different options has led to a preferred option: a CCCTB mandatory for large companies, equipped with an 'Allowance for Growth and Investment' and with an allowance for research and development expenses.

    The anticipated economic benefits of the proposal are positive, leading to an increase in investment and employment of up to 3.4% and 0.6%, respectively. Overall, growth would increase by up to 1.2%. 

    CONTENT: the proposal is the 'second step' in a staged approach towards an EU-wide corporate tax system with cross-border consolidation of the tax results amongst members of the same group.

    Scope: in contrast to the proposal of 2011, which laid down an optional system for all, this proposal will be mandatory for groups of companies beyond a certain size (whose consolidated turnover is above EUR 750 million). The threshold is in line with the approach taken in other EU initiatives to counter tax avoidance.

    At the same time, the common rules will be available, as an option, to a wide scope of groups that fall short of the size threshold. This allows SMEs and micro-enterprises the opportunity to benefit from the advantages of a CCCTB without making it compulsory for this set of companies.

    Definition of group: (unchanged compared to the proposal of 2011): eligibility for the consolidated tax group will be determined in accordance with a two-part test based on (i) control (more than 50% of voting rights) and (ii) ownership (more than 75 % of equity) or rights to profits (more than 75 % of rights giving entitlement to profit). These thresholds must be met throughout the tax year; otherwise, the failing company will have to leave the group immediately.

    Business reorganisations and taxation of losses and unrealised capital gains: the proposed framework chiefly involves the treatment of losses and unrealised capital gains on entering and leaving the group.

    There are rules to deal with unrealised capital gains which have accrued to fixed assets where the assets are disposed of within a short period after their entry into, or exit from, a group. A Member State (in the case of an entry into a group) or the group (in the case of an exit from a group) are given the right to tax underlying capital gains to the extent those were created in their tax jurisdiction. Moreover, the tax treatment of capital gains engrained in self-generated intangible assets calls for a customised approach, which will involve assessing them on the basis of a suitable proxy, that is to say, research and development, and marketing and advertising costs over a specified period.

    Withholding taxes (unchanged compared to the proposal of 2011): the proceeds of withholding taxes charged on interest and royalty payments made by taxpayers will be shared according to the formula of that tax year. Withholding taxes charged on dividends will not be shared.

    Preventing circumvention of tax exemptions (unchanged compared to the proposal of 2011): the tax exemption in favour of disposals of shares will be disallowed if this is illegitimately extended to sales of assets other than shares.

    Formula for apportionment: one of the principal elements of the proposal is the formulary apportionment, comprised of three equally weighted factors (i.e. labour, assets and sales by destination). This combination reflects a balanced approach to distributing taxable profits amongst eligible Member States.

    Administrative procedures: in contrast to the proposal of 2011, the common administrative rules are limited to the consolidated group.

    Groups will deal with a single tax administration in the EU ('principal tax authority' or 'one-stop-shop'.) This will be based in the Member State where the parent company of the group ('principal taxpayer') is resident for tax purposes. Audits will be initiated and coordinated by the principal tax authority.

    DELEGATED ACTS: the proposal contains provisions empowering the Commission to adopt delegated acts in accordance with Article 290 of the Treaty of the Functioning of the European Union.

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    See also
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    Directive
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    Common consolidated corporate tax base (CCCTB)
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    CNS - Consultation procedure
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    3.45.04 Company taxation