Part 1 - AL-Tax
Part 1 - AL-Tax Part 1 - AL-Tax
Chapter 8Relative CIT rate change 1995–2004 (in %)20100−10−20−30−40−50−60−70−70−60SK−50EELUITPL−40−30−20−10UKCZCYLV0NLSEDK HUDE10PT20FRGRE3040SEFIAT MTLT50607080ES90100Relative change in CIT collected on GDP 1995–2004 (in %)Sl: no change in CIT rate but a 23.3% increase in revenuesFigure 8.4 Evolution of corporate tax rates and revenue as percentage of GDP (1995–2004).Source: European Commission and own calculationsUnion. This ambiguity has of course translated into the political debate and isreflected in the tax proposals made by the European Commission.8.6 The corporate taxation debate in the EuropeanUnion: The early proposalsThe debate over EU corporate tax harmonization is not new. One should keep inmind that a similar debate was previously held on taxation of capital (interestand dividend payments) with parallel arguments and that the first formal proposalsto harmonize or coordinate corporate tax systems in Europe date from as far backas the early 1960s, when the fiscal and financial committee set up by the Commissionand chaired by Professor Fritz Neumark proposed in July 1962 – after two yearsof work – to gradually harmonize tax systems in Europe, starting with turnovertaxes and then doing the same with direct taxes with a split-rate system. However,the proposal was not followed by policy action. In 1970, another committeechaired by Professor Van den Tempel analyzed the various tax systems in placein the Member States and recommended that all adopt the classical system. 10 Thisproposal came shortly after the Werner Report on economic and monetary unionin Europe, which stressed that tax harmonization should accompany the creation187
International Taxation Handbookof a monetary union. Two Council resolutions followed in 1971 and 1972 whichagreed that it was necessary to proceed with fiscal harmonization. Driven by thismomentum, the European Commission proposed in 1975 to harmonize the corporatetax rates between 45% and 55% (Radaelli and Kraemer, 2005). 11 Interestingly,this proposal was challenged in 1979 by the European Parliament, whose agenda(as set out in the Nyborg Report) was to harmonize tax bases before tax rates.Measures to do just that were incorporated in a 1988 proposal by the EuropeanCommission but, because of the strong opposition of some Member States, it wasnever formally sent to the Council. According to Radaelli (1997), the harmonizationof corporate taxation in Europe slowed down from 1989, when CommissionerChristiane Scrivener took the taxation portfolio, as she preferred to focus on fightingdouble taxation – notably in cross-border operations of companies and in taxationof savings – and stressed the need for subsidiarity. The 1975 proposal was withdrawnin 1990. The next step took place in 1992, when another committee, this timechaired by Onno Ruding, was given a mandate to look at whether differences incorporate taxes distorted investment decisions. The committee proposed someminimum standards in corporate tax bases and a band for tax rates of between30% and 40% (Ruding Report, 1992). However, once again, this proposal was alsonot translated into political action.During all these years, the European Commission was battling on two fronts(Radaelli and Kraemer, 2005). First, it had to solve the problem of tax evasion, notonly to low-tax third countries, but also and foremost within the European Union,where savings of nonresident European were generally untaxed. Second, it had toovercome the problem of tax obstacles to the Single Market. These concerns ledto proposals on the taxation of savings and on the taxation of various cross-borderoperations.8.7 The corporate taxation debate in the EuropeanUnion: The 2001 CommunicationThe prospects for more coordination in corporate taxation were revived in 2001,when the European Commission issued a communication on company taxationin the Single Market (European Commission, 2001a). The communication wasaccompanied by a study on the level, dispersion, and determinants of corporateeffective tax rates in the EU-15, and itself made concrete policy proposals basedon the identification of a series of tax obstacles to the completion of the SingleMarket, the presence of excessive tax administrative costs, double-taxation188
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Chapter 8Relative CIT rate change 1995–2004 (in %)20100−10−20−30−40−50−60−70−70−60SK−50EELUITPL−40−30−20−10UKCZCYLV0NLSEDK HUDE10PT20FRGRE3040SEFIAT MTLT50607080ES90100Relative change in CIT collected on GDP 1995–2004 (in %)Sl: no change in CIT rate but a 23.3% increase in revenuesFigure 8.4 Evolution of corporate tax rates and revenue as percentage of GDP (1995–2004).Source: European Commission and own calculationsUnion. This ambiguity has of course translated into the political debate and isreflected in the tax proposals made by the European Commission.8.6 The corporate taxation debate in the EuropeanUnion: The early proposalsThe debate over EU corporate tax harmonization is not new. One should keep inmind that a similar debate was previously held on taxation of capital (interestand dividend payments) with parallel arguments and that the first formal proposalsto harmonize or coordinate corporate tax systems in Europe date from as far backas the early 1960s, when the fiscal and financial committee set up by the Commissionand chaired by Professor Fritz Neumark proposed in July 1962 – after two yearsof work – to gradually harmonize tax systems in Europe, starting with turnovertaxes and then doing the same with direct taxes with a split-rate system. However,the proposal was not followed by policy action. In 1970, another committeechaired by Professor Van den Tempel analyzed the various tax systems in placein the Member States and recommended that all adopt the classical system. 10 Thisproposal came shortly after the Werner Report on economic and monetary unionin Europe, which stressed that tax harmonization should accompany the creation187