El impuesto sobre sociedades en la Unión Europea y la propuesta de armonización mediante una base imponible consolidada común

Member States have freedom to stablish their own direct taxation systems, this lead to the coexistence of 28 different corporate tax regimens across the European Union (eu), which made cross border business to assume high fulfilment costs. In order to ease the burden and promote the functioning of the common market, the European Commission have proposed the implementation of a Common Consolidated Corporate Tax Base (ccctb) which aims for partial harmonization of the corporate tax and is expected to avoid double taxation and double non-taxation. However, the analysis of the proposal presented in 2011 suggests that this cannot eliminate the tax obstacles that affect the eu common market even though this is its main purpose. The ccctb implementation just in its current state do not eliminate high prices that come from the application of transfer pricing, the distribution of the tax base among Member States can result inequitable, mainly because of the labour factor and, there are substantial gaps regarding various procedural aspects of its implementation.