This is a real “big bang” tax that awaits Europe if the draft Ccctb directive, presented on Wednesday by the european Commission, goes to its end (” Les Echos ” of the 26/10/2016). Behind this acronym hides the ambition to harmonise the rules for the tax base on the companies, so as to put an end to practices of tax optimization. This would be a first step, before a second, even more ambitious, which would be to consolidate this base, to distribute the tax base among european States according to a distribution key economic. If France actively supports this project, however, it is not ensured to be a winner. The study of the impact of the commission revenue a negative impact on the revenue of corporation tax of 0.13% of G DP, even if this estimate is surrounded by many methodological precautions. This suggests that the basis at the european level is less wide than the base French.
The main concern related to this directive focuses on the French regime of fiscal integration, rather favorable. the ” The accounting of this regime with the european law is disputed, as shown by the litigation in progress. If the base is harmonised at the european level, this mismatch will become even more problematic, “, peak Gianmarco Monsellato, associate at Taj. The plan may even need to disappear eventually. the ” We are going to reduce its scope to all businesses that they will not be affected by the Ccctb “, said Jean-Pierre Lieb, partner at EY. In fact, the common tax base would apply compulsorily to companies with more than 750 million turnover. For others, this would be optional.
heated Discussions with Brussels
The other big unknown relates to the future tax credits. And France is playing a lot : anything that the research tax credit and CICE represent more than 35 billion of tax relief. the ” In practice, it will not be possible to keep them “, stresses Guillaume Roty, analyst of the european Commission representation in France. Bercy does not have this interpretation, which will be heated discussions with Brussels.
These new rules could still reserve a good surprise for the French companies. the ” The project does not cap mechanism for the deferral of deficits. As regards the rules of limitation of the deductibility of loan interest, they could be simplified, shows Jean-Pierre Lieb. in The directive also introduces the possibility to deduct the provisions for retirement, which could be interesting for French companies. “ Among the other advantages is also the idea of introducing a system of notional interest, attributable in fact to grant a tax benefit on the capital increases, as is the case for the debt. This type of regime already exists in Belgium and Italy, but not yet in France.
first of all, it is mostly in terms of fiscal stability that this directive might also be beneficial. the ” In the case of an agreement at the european level, there will be a more predictable tax, since the directive may not be constantly to be modified, “, stresses Guillaume Roty. For France, this harmonization should ask more clearly the question of the rate of the SI : ” Since the plates will be harmonized, the rate IS going to take an even more important place in the criteria of attractiveness “, writes Guillaume Roty.
Ingrid Feuerstein, Les Echos
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