L'imposition des entreprises multinationales en Europe: de la taxation séparée au modèle ACCIS

At many occasions the European Commission has expressed its willingness of enabling companies operated in the territory of the European Union to be taxed on a common corporate consolidated tax base (ccctb); recently a proposal of directive has been submitted et already discussed at the European Parliament. The debate is thus open: consolidation of the tax base and its distribution among member states according to a pre-established formula (Formulary Apportionment) could ease the operation of the internal market of the European Union, by eliminating tax obstacles to that good functioning,while simultaneously respecting the right for each member state to decide in a sovereign way on the corporate income tax rate to be applied on the fraction of the common consolidated base that it receives; moreover an appropriate design of the formula could reduce the risk of tax competition. The present contribution aims at highlighting the debate.