Thin Capitalization Rules in the Context of the CCCTB

Rita de la Feria () and Ana Paula Dourado
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Rita de la Feria: Oxford University Centre for Business Taxation
Ana Paula Dourado: Faculty of Law, University of Lisbon

No 804, Working Papers from Oxford University Centre for Business Taxation

Abstract: In the context of the proposed European CCCTB there is clearly a perceived need for the introduction of a common thin capitalization rule. This rule would be aimed at dealing with inbound investment emerging from both third countries, and from Member States opting out of the CCCTB. The principal aim of this paper is to establish whether such a need does indeed exist, and if so, which considerations should guide the design of a thin capitalization rule for the CCCTB. The paper starts by providing a broad summary of the varying approaches of Member States to thin capitalization. It then makes the case for the introduction of a thin capitalization rule in the context of the CCCTB, from both an economic and a legal perspective, and sets out the general principles which should guide the design of such a rule.

Keywords: Thin capitalization; CCCTB (search for similar items in EconPapers)
Date: 2008
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