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France and Germany seek ‘actual tax convergence’

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In a joint position paper, France and Germany have set out their proposed approach to a common corporate tax base (CCTB) for the EU, with some notable modifications to the European Commission’s latest CCTB proposal.

The so-called ‘Meseberg Declaration’, published on 19 June, is a wide-ranging statement of a vision for Franco-German cooperation in economic, social and fiscal matters, as well as foreign policy, security and defence. In relation to taxation, the two countries agree ‘to put in place actual tax convergence between France and Germany regarding corporate tax’.

The Franco-German plan for the CCTB, while aiming to ‘support and accelerate’ the Commission’s proposal, would introduce it without a revenue threshold, applying it to all corporate entities, regardless of size. France and Germany would like to see cross-border loss relief dropped altogether, and would exclude tax incentives for research and development and equity financing.

The declaration also includes the commitment ‘to reach an EU agreement on a fair digital taxation by the end of 2018’.

There is a further proposal for allocation of tax revenues to a Eurozone budget, within the framework of the EU, starting in 2021.

France and Germany intend to anchor their bilateral cooperation in a new ‘Elysée Treaty’ by the end of 2018.

Miles Dean, managing partner of Milestone Tax, sees the possibility of a ‘fast track’ CCTB brought in by a group of member states prepared to follow France and Germany. He suggests Spain and Italy might also ‘look favourably on this new proposal’.

See https://bit.ly/2N1RJsZ.

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