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The Act includes very few provisions aimed at reducing non-tariff barriers (NTBs). Lack of such provisions undermines the effectiveness of the Act, since reducing NTBs is essential to achieving a truly single market.
A number of proposals of the Act aim to reduce market barriers that arise naturally. For example, enterprises in different Member States may have different policies regarding electronic commerce, some may choose not to ship their products abroad due to higher risk of non-payment. Higher risk may mean a higher threshold to trade, which is natural and should not be tackled by regulation, as it is aimed to do by proposal No. 5. Thus, in creating a single market, the European Commission‘s goal should be to remove only state-imposed barriers to the single market, rather than to impose pan-European regulation of all enterprises within the EU. A convergence of the local markets can already be observed within the Union and the EC should not be focusing on reducing those barriers that arise (as well as disappear) naturally.
In particular, we would like to address proposal No. 19 to introduce a common consolidated corporate tax base (CCCTB). First of all, CCCTB will not help to achieve the aimed-at objectives of ensuring a smooth functioning of the common market, reducing the administrative burden or building transparency of tax rules. CCCTB will serve, and is already serving, as the first step towards a uniform tax policy in the EU, which will undermine tax competition inside the EU and weaken the region’s competitiveness in the global economy. It will render the corporate tax base even more complicated and, possibly, even more distinct from the international accounting standards, while, if being optional, it would only increase the number of standards within the EU. CCCTB will create enormous tax-compliance costs to business, especially small- and medium-sized enterprises, thus undermining the goal of the EC to improve business conditions for SMEs.
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