Corporate Tax Harmonization: Key Issues for Ensuring an Efficient Implementation of the CCCT

Most studies on the Common Consolidated Corporate Tax Base (hereinafter CCCTB) focus on whether the most appropriate quantification of the tax base has been chosen and on the prediction of inherent tax or economic effects. However, other problems concerning the implementation of a harmonized corporate income tax should be taken into account. Firstly, genuine fiscal neutrality ought to be established. Implementing a corporate income tax able to reach the objectives of tax revenue is crucial, even more given the different needs of the various Member States (hereinafter MS) by using a fair and objective system besides the relationship between taxpayers and the administration should be regulated. At the same time, articulating the relationships between different administrations to the existence of a uniform interpretation is a must. Finally, designing a conflict management system to apply equally to all citizens is essential.