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By Sami Douénias, partner, International Tax Leader, PwC Luxembourg and Ilaria Palieri, manager, PwC Luxembourg
The topic of loss compensation in the EU is an important matter, which has an immediate impact for multinational groups that operate in various Member States of the EU. Indeed, the possibility to offset losses arising in a Member State against profits that arise in another one is quite appealing to international groups. A few years ago, the EU Commission tried to propose a Directive (i.e. the proposal for a Council Directive on a Common Consolidated Corporate Tax Base(1)) to address this on a larger scale, but so far the Proposal has made little headway. This lack of progress also reflects the Member States’ reluctance to address this subject which could have...
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