The European Commission is to consider moves towards a mandatory corporate tax base across the European Union, RTÉ News has learned.
The idea comes amid deepening activity at EU level on the corporate tax issue, following recent allegations that multinationals have been involved in sophisticated schemes to avoid paying tax.
According to a discussion paper, seen by RTÉ News, the Commission will examine the idea of a mandatory corporate tax base, so that there are common rules across the EU on which part of a company's profits can be taxed.
The paper describes the idea of a mandatory corporate tax base as "fundamental".
However, this would not be the same as a common tax rate, officials stress.
Following the so-called Luxleaks scandal, which revealed a system of alleged corporate tax avoidance involving some 300 companies and operating through Luxembourg, the Commission has been planning for some time to re-launch tighter rules on corporate taxation.
The Commission will publish its plans on 17 June, with all 28 commissioners - including Ireland's Phil Hogan - debating the issues tomorrow.
The discussion paper, which has been circulated among commissioners, suggests making a common corporate tax base "mandatory" to prevent multinationals shifting profits from one member state to another in order to minimise their tax liability.
A common tax base would mean harmonised rules on what can and cannot be offset against company profits for tax purposes.
The idea of creating a common tax base has been in the pipeline of EU legislation for several years, but it has been hampered by a lack of consensus among member states.
The issue looks in particular at how and where multinationals, which may have subsidiaries in several EU member states, pay tax and on what.
Part of the approach has been to make the tax base "consolidated."
This would mean adding up all the profits and losses of a company or group of companies with operations in different member states, in order to arrive at a net profit or loss for the whole of its activity in the EU.
An agreed formula would then be used to decide the final taxable base of the company or group of companies.
However, the formula method has proved highly contentious in discussions between member states and the European Commission in recent years.
For that reason, the Commission is considering postponing that element and in the meantime making a straightforward corporate base mandatory.
Although the Government here has long had reservations about CCCTB, it is understood that Dublin could see advantages in a straightforward harmonised tax base.
The reasoning is that if a multinational has clarity on the tax base in each member state it can then chose a country which has the most attractive corporate tax rate.
Government sources also denied a report in the German paper Handelsblatt that the Commission will propose a minimum corporate tax rate following pressure from Germany and France.
It is understood, however, that the Commission will discuss the idea of requiring multinational corporations to publish the tax arrangements they have in each member state.
The practice in several OECD countries is for multinationals to provide such information to the tax authorities, but not to make it publicly available.
It is understood the Government would have reservations about multinationals publicly disclosing tax arrangements as it would increase their regulatory burden.
Ireland is currently being investigated by the European Commission for is tax arrangements with Apple.
The Commission believes that two tax deals between Apple and Revenue in 1991 and 2007 amounted to preferential treatment, and therefore illegal state aid.
The Government has denied the charge and has vowed to challenge any finding against it at the European Court of Justice in Luxembourg.
The Netherlands and Luxembourg are also being investigated in relation to alleged tax rulings with Starbucks, Amazon and Fiat respectively.
Taxation remains a national competence with member states enjoying a veto on any EU tax rules.
Due to the lack of agreement on CCCTB there was a proposal that a group of countries could forge ahead on their own with a CCCTB according to the method known as "enhanced cooperation."
Because tax remains a national competence there is some scepticism that a common tax base could be made mandatory.
Following the financial crisis in 2008-2009 the European Commission pushed the idea of CCCTB as a way of boosting the single market and the European economy, since harmonising the rules would give multinationals clarity when deciding to invest in the EU.
However, the issue failed to gain widespread support among member states.
Despite that, growing public disquiet over global corporations allegedly avoiding their tax obligations has pushed the issue centre stage once again.
