The meaning of ‘resident taxpayer’ and ‘non-resident taxpayer’ under the proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)

The paper covers the meaning of ‘resident taxpayer’ and ‘non-resident taxpayer’ under the proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) with a focus on the complex rules dealing with its personal scope. Bearing in mind the many features of the Proposal, which are commented on in the paper, the meaning is examined of the expressions ‘resident taxpayer’ and ‘non-resident taxpayer’, which are rather intricate insofar as they both include references to other defined expressions or terms. The paper suggests revisions that may provide clarity and simplification while upholding the use of tax treaty definitions.