2018年-CEPS欧洲政策研究中心_An_EU_Company_without_an_EU_Tax_38页_117kb
报告摘要
Summary of "AN EU COMPANY WITHOUT AN EU TAX?"
Core Content
This report, authored by Karel Lannoo and Mattias Levin, addresses the issue of corporate tax harmonisation within the European Union (EU) and its importance for achieving the goals of the Lisbon Process. It outlines a Corporate Tax Action Plan aimed at improving the Single Market by reducing the complexity and inefficiencies caused by the current fragmented tax system across EU member states.
Main Viewpoints
- Corporate Taxation in the EU: The EU has 15 different corporate tax systems, each with varying rates and methods of calculating taxable profits. These differences create significant compliance costs and distort economic decisions.
- Impact on Competitiveness: The current tax system hinders the competitiveness of European industry due to high compliance costs, double taxation, and protectionist regulations. It also reduces the pressure on tax administrations to adapt.
- Need for Tax Coordination: Tax harmonisation is essential for the EU to become the "most competitive economy in the world" by 2010. The European Company Statute (ECS) presents an opportunity to move towards a more coordinated system, but without a unified tax base, its benefits may be limited.
- Tax Competition and "Race to the Bottom": While tax competition is often viewed as beneficial, it can lead to a "race to the bottom" in tax rates or revenues. However, empirical evidence does not show a significant decline in tax revenues despite lower nominal and effective tax rates.
- Shift in Tax Burden: There is a noticeable shift in the tax burden from corporations to individuals and social security contributions, which may affect employment and economic efficiency.
- Compliance Costs: The cost of compliance with the current tax system is estimated to be between 2% and 4% of total corporate tax revenues, amounting to approximately €4.3bn to €8.6bn for the EU. This is likely an underestimate due to the complexity of 15 different systems.
Key Information
Current Corporate Tax Situation in the EU
- Tax Rates: Corporate tax rates vary significantly across EU member states, ranging from 10% (Ireland) to 39% (Belgium) in 2001.
- Effective Tax Rates (EATR): These are generally lower than nominal tax rates and have decreased over the years, but the divergence between countries remains.
- Tax Calculation Methods: Differences in accounting systems, treatment of dividends, capital gains, depreciation, and sector-specific regimes contribute to the complexity of the system.
Consequences of the Current Situation
- Economic Distortions: Tax differences influence investment decisions, often leading to tax-driven investments rather than cost-driven ones.
- Compliance Costs: These are substantial and affect the efficiency of corporate operations.
- Tax Burden Shift: The effective tax burden on capital has decreased, while that on labour has increased, with a notable rise in social security contributions.
Proposed Corporate Tax Action Plan
| Timing | Proposal | Advantages | Deadline |
|---|---|---|---|
| Long-term | Common Tax Base | Transparency, efficiency, effectiveness | 2010 |
| Medium-term | Home State Taxation (HST) | Politically feasible, simplification | 2010 |
| Medium-term | Optional Common Base Taxation (CBT) | Politically feasible, step towards CBT | 2010 |
| Short-term | Adapt parent/subsidiary and merger directives | Include SEs, improve implementation | 2003 |
| Short-term | Harmonise intra-EU tax treaties | Reduce tax planning, adapt to EU reality | 2005 |
| Immediate | Coordinate implementation of ECS | Ensure benefits of ECS materialise | Now |
| Immediate | Adoption of the draft interest/royalty directive | Harmonise tax treatment of transfers | Now |
| Immediate | Ratification of the prolongation of the Arbitration Convention | Resolve transfer pricing disputes | Now |
| Immediate | Prolongation of the Code of Conduct | Continue efforts to eliminate harmful tax practices | Now |
Institutional Barriers
- Political Support: EU member states are not fully committed to further tax harmonisation, which hinders progress.
- Institutional Reform: The Convention on the Future of Europe should address institutional obstacles by extending qualified majority voting in tax matters to enable faster decision-making.
- EU Enlargement: The EU's focus on enlargement may delay further tax reforms, making it imperative to act now to maintain momentum.
Conclusion
A more harmonised corporate tax system is essential for the EU to achieve its economic goals and improve the efficiency of cross-border business. The proposed Corporate Tax Action Plan outlines immediate and long-term steps to move towards a single tax base, reduce compliance costs, and ensure that the benefits of the European Company Statute are fully realised. The report stresses the need for decisive political and business support to overcome existing challenges and promote a more integrated and effective corporate tax system in the EU.
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