K22 - Business and Securities LawReturn

The introduction of the CCCTB system in the European Union will have the impact on the redistribution of the group tax bases between the Member States and therefore also on the national budgets. The aim of the paper is to quantify the differences in the division of the MNEs group tax bases between the individual Member States in current situation - i.e. when applying separate entity approach and situation when CCCTB will be introduced - i.e. applying the allocation formula for sharing the tax base. The results show that the Czech Republic could gain in situation when CCCTB would be introduced in all EU Members States - the share in the group tax base would increase by 1.22%. A very slight increase was also indicated in the case of the Slovak Republic, Slovenia and Spain. On the contrary, the share in the group tax base was decreased in the case of Germany (by 1.36%), Estonia, Hungary and Poland. The results also indicate that there might be connection between the size of the country and the impact on the share of the tax base.