比利时共同企业税基对有效税负的影响外文翻译资料

附录B 外文原文

Impact of a Common Corporate Tax Base on

the effective tax burden in Belgium

Abstract

In March 2011, the European Commission launched a proposal for a Common Consolidated Corporate Tax Base (CCCTB). However, a Common Corporate Tax Base (CCTB), leaving consolidation and apportionment out of consideration, appears to be a more realistic proposition for corporate tax harmonization in Europe. Using the European Tax Analyzer (ETA), we simulate the impact of the CCTB on the effective tax burden in Belgium. The results show that the adoption of the CCTB increases the Belgian effective tax burden by 16%. This remarkable increase is mainly driven by the fact that national tax deductions are not allowed under CCTB. This study allows policymakers to gain insight into the size effects of certain corporate tax measures and contributes to the current discussion on corporate tax harmonization in Europe.

Key words: CCTB, effective tax burden, Belgium, simulation, ETA, CCCTB

1.Introduction

In March 2011, the European Commission (EC) launched a proposal for a Common Consolidated Corporate Tax Base (CCCTB) (EC 2011). The goal of this optional tax system is to remove the underlying causes of all tax obstacles currently harming the international competitiveness of European multinationals (EC 2001). The tax liability of a company belonging to a CCCTB group would be determined by applying four distinct steps. Firstly, each group member has to calculate its taxable profit according to the same set of rules, i.e. the Common Corporate Tax Base (CCTB). Secondly, the individual tax bases are summed up to the consolidated tax base while taking into account the elimination of intra-group transactions and loss compensation. Thirdly, the consolidated tax base is allocated to the different group members by means of an apportionment formula. Finally, each member state has the right to apply its own tax rate to the specific share of the overall tax base (Schouml;n et al. 2008). Recent studies (Bettendorf et al. 2010) exploring the macro-economic impact of introducing a CCCTB find that the system would not yield substantial welfare gains for Europe. The variation of welfare effects across countries is large and highly depends on the design of the apportionment formula. A less-far reaching and therefore more achievable approach would be the introduction of a CCTB. This policy option would affect the calculation of the corporate tax base by introducing a common set of tax accounting rules for all member states. At a later stage, consolidation and apportionment of the individual tax bases could be included, which transforms the CCTB into a CCCTB system. As some member states have clearly expressed scepticism about the feasibility of CCCTB, the CCTB approach appears to be a more realistic proposition for corporate tax harmonization in Europe (Oestreicher et al. 2009). In this respect, also the FrenchGerman intention to introduce a harmonized tax system could have an impact on the implementation of a CCTB in Europe1. Using the European Tax Analyzer (ETA), Spengel et al. (2012) simulate the impact of a CCTB on the effective tax burden of companies in all 27 EU member states. The results show that the effective tax burden would, on an EU average, remain largely unchanged (–0.06%). One of the great merits of the study of Spengel et al. (2012) is that the effective tax burden effect is measured for each of the EU member states. Moreover, this large-scale approach gives the opportunity to assess the effective tax burden for Europe as a whole. However, such an approach is very time-consuming and a limitation of this study is that it is unfeasible to address all national tax regulations in great detail. Also, the study of Spengel et al. (2012) explains the most important differences between the losing and winning countries and does not have the intention to stress the tax burden effect for one country in particular. Our research contributes to the existing literature in two ways. First, contrary to the previous literature, we focus on the impact of a CCTB on the effective tax burden for Belgian companies in particular. Specifically, we compare the effective tax burden under CCTB with the tax burden under the Belgian tax system and investigate the isolated impact of the implemented tax measures. In order to do this, we extent the latest version of the ETA taking into account the Belgian tax measures stimulating Ramp;D. We also implement particular measures for SMEs like the increased percentage for notional interest deduction and the reduced tax rates. As regards CCTB, we apply all rules as recently proposed by the EC (EC 2011). These rules, for example, deal with assumptions concerning depreciation and valuation of inventories. Second, we contribute to the existing literature by studying under which conditions the CCTB could be an attractive choice for Belgian companies and by including policy recommendations that could be relevant for other European countries. In general, the results show that the adoption of the proposed CCTB remarkably increases the tax burden by 16%. This finding is mainly driven by the fact that Belgian companies are not allowed to apply the notional interest deduction under CCTB.

1. Research set-up and methodology

In this paper, we focus on the impact of a CCTB on the effective tax burden for Belgian companies in particular and examine the following research questions: – To what extent does the effective tax burden for an average company differ when applying CCTB instead of the Belgian tax system? – What is the size of the impact on the tax burden when the implemented tax rules of CCTB and

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