Manon Aubry

Article 3a Significant economic presence 1. For the purposes of corporate tax, a permanent establishment shall be deemed to exist if a significant economic presence exists through which a...

(a) all buildings as well as any other type of immovable property and structure in use for the business, with the exception of industrial buildings and structures: 30 years;

(10c) A fairer taxation of passive income also requires robust Controlled Foreign Company (CFC) rules for BEFIT group members in order to make them more resilient against profit shifting.

(25a) In line with the legally binding roadmap on new own resources set out in the Interinstitutional Agreement of 16 December 2020 and the 2021 Commission Communication "An adjusted package...

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(3a) Harmonising the corporate tax base through a common set of rules improves transparency, thereby fostering a fairer and healthier tax environment within the Union, which is underpinned in...

Article45h Sales by destination 1. Sales of goods shall be included in the sales factor of the BEFIT group member located in the Member State where the dispatch or transport of the...

(10b) To guarantee a minimal level of PE778.803/ 11 taxation of royalties, a royalties limitation rule for BEFIT group members should be introduced in accordance with the Subject to Tax Ruleas...

(18) To ensure that the rules of the common framework are implemented and enforced correctly, Member States should lay down rules on penalties applicable to infringements of national provisions...

(21b) The Commission should, where appropriate, submit a legislative proposal for a harmonised, common European taxpayer identification number. This would not only facilitate the PE778.803/ 18...

(b) the head office of the permanent establishment is either the ultimate parent entity of the group or any other member (company or entity) of the group in which the ultimate parent entity holds,...

The financial accounting net income or loss of a BEFIT group member shall be adjusted in accordance with Article 16(1), PE778.803/ 23 point (e), of Directive (EU) 2022/2523.

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(ea) extending the concept of a permanent establishment, to include a significant economic presence through PE778.803/ 19 which a business is wholly or partly carried on.

(1) Within the Union there is currently no common approach to the computation of the taxable base for businesses. Therefore, Union businesses are obliged to comply with a different corporate tax...

(8a) This Directive should lay down rules extending the concept of a permanent establishment so as to include a significant economic presence through which a business is wholly or partly...

Penalties shall be set at a minimum of 0,5 % of the turnover of the BEFIT group for any failure to file the BEFIT information return pursuant to Article 59.

(9) The objective of simplifying the current rules underscores the envisaged PE778.803/ 9 initiative, improving the efficiency and competitiveness of the internal market....

(14a) The Commission and the Member States should ensure the coherence and alignment of this Directive with the OECD/G20 Model Rules and with Directive (EU) 2022/2523, in particular as regards...

(15) Some Member States operate corporate tax systems which are built on principles that differ from the most common approach, such as distribution- based tax systems. It is therefore of prime...

(18a) A key pillar for improving corporate tax compliance is the establishment of a comprehensive one-stop-shop system that enables businesses to fulfil their tax obligations across Member...

(21a) To guarantee efficient cooperation among BEFIT teams, Member States should dedicate adequate human resources to the BEFIT team, including by providing content and language training to...

2. Member States shall communicate to the European Parliament and to the Commission relevant information for the evaluation of the Directive in accordance with paragraph 3, including...

Article 21a Controlled foreign companies 1. The financial accounting net income or loss of a BEFIT group member shall be adjusted to include the non- distributed income of an entity or...

Where a company or a permanent establishment enters a BEFIT group, any unrelieved losses incurred up to five years before the entry date, in accordance with the corporate tax law of the...

Article 16a Entertainment costs The financial accounting net income or loss of a BEFIT group member shall be adjusted to include 50% of the amount of expenses accrued for entertainment...

(3) Albeit different in their design, the fundamental features of corporate income tax systems are similar as they lay down rules aiming towards the same objective, i.e., to arrive at a taxable...

Article 45e Allocation of assets 1. Without prejudice to Article 22(2) and (3), an asset shall be included in the asset factor of its economic owner. Where the economic...

(10a) In order to achieve the objective of a simplified tax framework and in order for this Directive to adequately complement Council Directive (EU) .../..., the rules laid down in this...

(aa) industrial buildings and structures: 25 years;