• Service: Tax, International Corporate Tax
  • Type: Press release
  • Date: 11/30/2011

CCCTB a serious proposal: New KPMG Guide provides clear overview of the main provisions and issues 

History shows that harmonizing direct taxes within the European Union (EU) is anything but fast and easy. And, despite the political and technical obstacles, the EU Commission’s Proposed Directive on Common Consolidated Corporate Tax Base (CCCTB) remains a serious proposal. Today, to provide clear, practical descriptions of the proposals, as well as thought-provoking insights into the technical aspects, KPMG’s EU Tax Centre released a new Guide to CCCTB.

As well as contributions from specialists from KPMG member firms around the world, The KPMG Guide to CCCTB includes contributions from a number of highly respected experts including: Judith Freedman, Professor of Taxation Law, University of Oxford; Graeme Macdonald, formerly University of Kent; Marius Vascega, Council of the European Union and Servaas van Thiel, Professor of International and European Tax Law, Free University of Brussels.

Since its publication, the proposed CCCTB Directive has met opposition from a number of Member States, either by way of the formal objection procedure, popularly known as the yellow card procedure, or informally through government statements. As insufficient votes were raised under the yellow card procedure, the Commission has not had to reconsider the proposal. However, in view of the unanimity required among Member States for the Directive to be adopted, its path clearly will not be easy. If and when the Directive is formally adopted by the European Council, it will then have to be implemented into the national tax systems of each Member State. The Commission envisages this process being completed in time for the CCCTB system to come into force from 2015 or 2016.

In addition to the substantive tax rules, it will also be necessary to implement procedural rules, procedures and systems for applying the new system. The practical difficulties—such as setting up a central database accessible to all EU tax authorities—should not be underestimated. Notwithstanding the political and technical obstacles, its practical implications for businesses, if it is introduced, would be huge.

“Businesses throughout the EU will need to clearly understand what the CCCTB proposal means for them,” says Barry Larking, head of knowledge management at KPMG’s EU Tax Centre and co-author of the Guide. “That requires not just a one-off exercise, but rather an ongoing, dynamic process.”

The KPMG Guide to CCCTB provides readers with an easily accessible, clear overview of the main provisions of the Directive, together with more in-depth insights into a number of specific issues.
It is divided into three parts:

  • Part 1 addresses the political background and the EU decision making process, as well as policy issues such as the CCTB alternative and the choice between specific rules, rather than general principles.
  • Part 2 generally follows the structure of the Directive and takes the reader through its essential details with practical examples and illustrations.

A Part 3 will be added over time, where appropriate, to reflect new developments and provide greater insight into selected technical and practical issues arising from the Directive.

The KPMG Guide to CCCTB, video interviews and regular updates on CCCTB as they are announced, please visit

For more information, please contact:

Carolyn Forest

KPMG International

+ 1 416 777 3857

About KPMG International

KPMG is a global network of professional firms providing Audit, Tax and Advisory services. We have 138,000 outstanding professionals working together to deliver value in 150 countries worldwide. The independent member firms of the KPMG network are affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. Each KPMG firm is a legally distinct and separate entity and describes itself as such.


The KPMG Guide to CCCTB

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The Guide discusses how, despite the political and technical obstacles, CCCTB is a serious proposal, and it deserves to be treated as such.