Mr. Bert Zuijdendorp:

Moving a parent out of the EU will not get a company out of the CCCTB and its mandatory application. In terms of the allocation of profits, it does not matter under the CCCTB where a company files its tax returns. That it may file in a member state with a low tax rate is of no consequence, given that the member state may only get a small share of the allocated profits. Having the main taxpayer in that member state does not mean that profits will be taxed at its favourable rate. The effect of applying the formula is that it does not matter where a company files its tax returns, as the allocation of profits is not decided on that basis, but on the basis of where its assets, payroll and-----