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Mr Frits Bolkestein

Member of the European Commission in charge of the Internal Market and Taxation

"Towards an Internal Market without tax obstacles"

European Commission conference on company taxation in the European Union, Charlemagne Building

Brussels, 29th April 2002

Minister Montoro

Members of the European Parliament

Ladies and gentlemen,

It is a true pleasure for me to welcome you here in Brussels to the "European Conference on Company Taxation".

The Commission has organised this conference in order to address one of the most burning issues at EU level today: how to achieve a true Internal Market without tax obstacles. This is no exaggeration. Although it may sound like a hackneyed phrase by now, it is true: Without determined action on the tax front, the EU will fail to achieve its self-imposed objective of becoming, in this decade, "the most competitive and dynamic knowledge-based economy in the world".

Commission strategy and topics of the conference

The overall Commission strategy for tackling the various tax obstacles in the Internal Market is effectively based on two legs:

  • a series of specific measures which are targeted at clearly defined obstacles and

  • the work towards a common consolidated EU tax base which forms the subject of this conference.

The first leg of this "two-track" strategy includes, for instance, measures like improving the Merger-Directive in order to resolve problems with cross-border restructuring operations.

The various initiatives under this heading do not form part of this conference.

This is not because we do not think that they are important. On the contrary, they are very important, certainly in the short run. However, work on these initiatives is progressing well in the appropriate working groups of the Commission and the Council.

Moreover, because of the traditional type of measure and the technical character of the work required for taking them further, they do not depend on such a broad political debate and support as does the idea of a "comprehensive solution" to the tax problems at EU level.

Finally, without questioning the value of the targeted measures in any way, it is the Commission's firm belief that only a comprehensive solution goes to the root of the various tax obstacles.

I should like to invite you to concentrate your contributions at this conference on one main subject : a common consolidated tax base for the EU-wide activities of companies.

Concept of a common consolidated tax base

In our view only this concept ultimately provides an answer to the challenges of company tax systems in the EU today.

The Commission therefore believes that companies with cross-border and international activities within the EU should in future be allowed to

  • compute the income of the entire group according to one set of rules and

  • establish consolidated accounts for fiscal purposes - thus eliminating the potential fiscal effects of purely internal transactions within the group.

Turning to the representatives from Member States I wish to point out that this approach by no means infringes the subsidiarity principle or Member States' sovereignty to set corporate tax rates. Member States would apply their national tax rate to their specific share of the overall tax base as computed according to a commonly agreed allocation mechanism.

The advantages of the consolidated corporate tax base for the EU-wide activities of companies are real and substantial:

The compliance costs resulting from the need to deal with 15 tax systems within the Internal Market will be significantly reduced.

Within the EU, transfer pricing problems will largely disappear.

Businesses will finally have the possibility of a comprehensive consolidation of profits and losses on an EU basis.

Many international restructuring operations will be simplified.

Without extending into the personal tax field, some of the complexities arising from the co-existence of the classical and exemption approaches to international taxation will be reduced.

Many situations of double taxation will be avoided.

Finally, many discriminatory situations and restrictions will be removed.

In other words: A consolidated corporate tax base

  • would reduce compliance costs for all stakeholders,

  • allow the EU to reap the full benefits of the Internal Market, and

  • increase the competitiveness of EU business.

Thus, it would lay the foundations for achieving the goals set by the Lisbon European Council which I mentioned at the beginning.

The various possibilities for achieving this important goal are, among many other things, presented and examined in detail in the thorough study which my services have compiled over the last couple of years with the assistance of two panels of external experts. I am very pleased to see that many of these experts are present today.

This study - "Company Taxation in the Internal Market" - was made available on our web-site last October and I hope that you have all taken the opportunity to look at it in preparing for this conference.

Today, on the occasion of this conference, the first printed versions in 'book' form are available from the Commission's publication office, "fresh from the printing press".

I should like to invite you to have a look at the copies, which are displayed for your information outside.

On a more commercial note, I can inform you that your conference folder also contains a leaflet with the necessary information for ordering copies.

I am confident that the conference will make progress and help us gain new insights into the medium-term objective of providing companies in future with a consolidated corporate tax base for their EU-wide activities. As I said, the Commission strongly believes that working towards this objective is the necessary way forward.

However, as you can see in our study, we are fully aware of the fact that there are different ways for realising this objective. In the study we have elaborated four potential models which are either based on a "mutual recognition" approach or rely on a limited form of harmonisation.

Each model has its specific advantages and shortcomings. Each raises complex technical and political questions. This is why we need a broad political debate. And this is why we need your expertise.

On the basis of this study and the Commission Communication, which was issued at the same time, we have organised the conference in three sessions. These are designed to address in a concrete manner those issues which need to be tackled before any reform can be implemented.

Session one addresses the fundamental question of the choice of the approach. Session two will consider the means for achieving a common tax base and in session three the problems of organising the transition to the new EU tax base in practice will be discussed.

Together with the conference programme you have all received a paper that explains the contents of these sessions in some more detail. I hope this will help to guide you through the debate.

I should especially like to thank all the representatives from Member States and the business world, be it from the consultant or industry community, who have agreed formally to participate in the conference as a panel speaker or to chair one of the sessions.

Obviously many others will wish to intervene, from Member States' tax administrations, from the business world and from the academic community. As you have seen in the conference programme, the panel sessions will therefore each be followed by a general discussion in plenary.

At the same time, I should very much like to encourage you to step forward and make your voice heard in the debate. You may have noticed that we have not appointed any Commission speakers. We, the Commission, with valuable input from our "expert panels", have produced the study and proposed in the October Communication a political strategy for addressing the remaining tax obstacles in the Internal Market.

Now it is up to you to provide your input in order to take the issue further. The Commission wants to listen to your views.

The outcome of this conference will be very important in order to decide how the plans for a fundamental reform of company taxation at EU level will be taken forward!

However, the discussion will not end here. These issues are far too complex and politically ambitious to be solved in a day and a half. There will have to be further debate and the Commission has even set up an electronic discussion forum in order to provide for a platform for further debate in the coming months.


Ladies and Gentleman,

I am pleased by the high degree of interest and participation, which the conference has attracted and which is further demonstrated by your presence. I hear that some conference participants have even flown several thousand kilometres to attend!

Without prejudging the day and a half ahead of us, I should think that this in itself shows that the Commission proposal of tackling the various tax obstacles in the Internal Market 'in one stroke', via some form of a common EU tax base, is seriously considered by all interested parties.

As your very presence here demonstrates, it is not "pie in the sky", as some have reportedly criticised it as being, but an admittedly ambitious but nevertheless necessary and, I hope, realistic approach.

Moreover, there are very encouraging recent developments like the agreement on the European Company statute.

It is in this spirit that I wish to once again to extend my warmest welcome to you all.

I am looking forward to an interesting and fruitful debate!

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