The CCCTB Rules on Leaving a Group

The consolidation system proposed in the draft of the CCCTB Directive puts relationships between Member States on edge. This is clearly apparent in the rules that apply when a company leaves a group. In this article the leaving rules are examined. Although the leaving rules are claimed to be 'tailor-made', their effects are just as rough as the allocation of the consolidated profit according to the apportionment formula. It remains very much a question as to whether there are sufficient advantages to balance this approach.