Group taxation – special schemes according to which a group of companies meeting certain requirements may be assimilated for tax purposes to a single company – exists in several European Member States and is now under consideration in an EU proposal concerning a common consolidated corporate tax base (CCCTB).
Its rationale as a potential EU tax regime has arisen from a series of high-profile ECJ cases concerning cross-border tax relief claims – decisions which have been criticized for lack of clarity and for breach of freedom of establishment (Article 49 TFEU). Group taxation has now become one of the most intensively debated issues in EU tax law.
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