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CFE/EU Liaison Group

Category CFE and Europe
The first meeting of the CFE/EU Liaison Group was held on 6 May 2003. The list of issues discussed appears below. 1. Pan-EU corporate tax

a. Are we in favour of harmonisation (planning opportunities vs. efficiencies)?
b. If so, which version: Home State Taxation, Common Base Taxation, EU Corporate Income tax, other?
c. What is our view on Home State Taxation for small and medium sized enterprises?
d. What is our view on formulary apportionment vs. the arm’s length rule?
e. Do we favour exemption methods, credit methods or both?
f. What is our view on interest allocation?

2. International Accounting Standards

a. Do we favour IAS as the starting point in the tax computation?

3. European Company

a. Do we favour a special tax regime for the European Company or do we want to see the removal of obstacles to its use under normal fiscal regimes?
b. Will taxpayers actually use the European Company once the obstacles are removed?
c. Do we favour a pilot study of European harmonised taxation? If so, should this be based on the European Company or something else?

4. Cross border loss relief mechanism

a. What is our view on cross border loss relief (should be introduced by directive, should be allowed to mature in the ECJ, should be discouraged as economically unrealistic)?
b. What is our position on the Marks & Spencer case?

5. Harmful taxation

a. What is our general view on Harmful Tax Competition/the Primarolo Group?
b. When is a tax rule/measure harmful?

6. Transfer pricing

a. What is our view of the actual costs of transfer pricing compliance etc.?
b. What is our view on Mutual Agreement Procedures?
c. What is our view on the Arbitration Convention?
d. What is our view on Advance Pricing Agreements?
e. What is our view on the UK/OECD positions on attribution of profits to permanent establishments?

7. Discrimination, Infringement of the Fundamental Freedoms

a. Is transfer pricing legislation contrary to EC law?
b. Is CFC legislation contrary to EC law?


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