Common Corporate Tax Base (CCTB) or Common Business Tax Base (CBTB): evaluation of economic impacts

Project directors

  • Prof. Dr. Christoph Spengel

Responsible for subprojects

  • Prof. Dr. Fuest
  • Prof. Dr. Oestreicher
  • Prof. Dr. Scheffler
  • Prof. Dr. Spengel

Participating research assistants

  • Dipl.-Kffr. Katharina Finke (ZEW)
  • Dipl.-Vw. Jost H. Heckemeyer
  • Dipl. Wiinf. Stefan Hohls
  • Gerrit Kimpel, M.Sc.
  • Dipl. Kffr. Melanie Köstler
  • Dipl.-Kffr. Claudia Krebs
  • Dipl.-Kffr. Dorothea Vorndamme
  • Dipl. Kfm. Benedikt Zinn


01/10/2012 – 30/04/2013

Funded by

  • Federal Ministry of Finance

Co-operating partner

  • Centre for European Economic Research

The EU-Commission presented a draft directive for a Common Consolidated Corporate Tax Base (CCCTB) on 16 March 2011. With a CCCTB the EU Commission pursues the target to remove essential tax barriers to the European internal market. The coexistence of 27 tax regimes, in particular leads to high administration costs that are linked to additional tax burdens. Further aspects cover the limited possibility of cross-border loss-offset and the need to determine intra-group transfer prices for tax purposes. Both double taxation and double non-taxation (so-called white income) issues as well as systematic tax avoidance by shifting profits to low tax countries are under consideration.
The draft directive of the EU Commission provides a broad concept to abolish these barriers. The main focus is on harmonized determination of income and on consolidation and formula apportionment of profits. Based on an earlier working document of the CCCTB working group, impact evaluations on parts of the concept have been worked out at the level of the European Union. As these impact evaluations already revealed first indications of the concept’s effects, they were taken into consideration by the Commission when finalizing the details of the draft directive. An evaluation of the directive itself still needs to be carried out, however. This is all the more necessary since in the meantime there have been reforms of the national tax regime changing the basis for an impact evaluation. Country-specific features, e.g. the relevance of partnerships and its potential integration into a CCTB/CCCTB, as proposed by the Bundesrat on June 6, 2011, have not yet been incorporated in the impact evaluation. Finally, the directive and the resulting discussions in trade and industry and among politicians bring to light the fact that there is a difference between a comprehensive CCCTB and a CCTB/CBTB (Common Corporate Tax Base/Corporate Business Tax Base) involving only domestic companies (i.e. without consolidation and formula apportionment). This research project focuses on the latter option. Nevertheless, a CCTB/CBTB also has consequences for international companies that are taken into account as well.