Document Type


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Corporate Taxation, Home State Taxation, CCCTB, Common Consolidated Tax Base, Formulary allocation, Unitary allocation, tax allocation, EU corporate tax reforms

Subject Categories

Comparative and Foreign Law | International Law | Law | Organizations Law | Tax Law


This Article examines the European Commission's Home State Taxation and CCCTB initiatives. It argues that both proposals undermine the long-term objective of attaining a consolidated European corporate tax regime. It suggests an alternative strategy, which offers a comprehensive formulary-tax-allocation-solution in one of the hard to tax sectors, such as the financial sector. This strategy requires more efforts and political risk-taking, but would better promote the long-term objective of a consolidated EU corporate tax regime.

An edited version of this article is scheduled to be published in a future issue of European Taxation (an IBFD publication).