The European Commission announced a new package of corporate tax reforms on October 25. The package includes three separate legislative initiatives. With respect to the Common Consolidated Corporate Tax Base (CCCTB) proposal, the Commission recognizes that elements of the original CCCTB proposals gave rise to difficult debates and consequently has proposed a staged approach. Accordingly, the proposal has been split into two directives, one covering a common corporate tax base (CCTB) and the other covering the CCCTB itself. Discussions on the draft directive relating to the CCCTB will be postponed until the elements of the CCTB are agreed. The first stage in the re-launched proposals contains a set of rules to create a CCTB but does not include consolidation rules. These are broadly the same as the relevant aspects of the 2011 proposals, though they have been updated to take into account the European Union's (EU's) work on the Anti-Tax Avoidance Directive (ATAD). The proposals now also incorporate a notional interest deduction and a super-deduction for research and development (R&D).

A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details.

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Full text of Tax Alert 2016-1819