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Fiscal measures aimed at encouraging cooperation between undertakings of different Member States. Communication from the Commission to the Council. COM (85) 360 final, 5 July 1985.

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COMMISSION OF THE EUROPEAN COMMUNITIES C~(85l 360 final Brussels, 5 Ju l y 1985 FI SCAL MEASURES AIMED AT ENCOURAGING COOPERATION BETWEEN UNDERTAKINGS Of DIFFERENT MEMBER STATES -----------·---------------------------------------------- Co~mun i eat1on from the Com~ission to the Council C~(85l 360 fina l /} 2. t ' c 6/1-"1. )/ ~ --'""'--: .. ~-·-· ---.. ---·-- .-.-·f.-l.SC.AL, •. MEASURES AIMED AT ENCOURAGING COOPERATION - --·--·-..:___:..._ ...... ·. _:"E:::;;__. __ BETWEEN UNDERTAKINGS OF DIFFERENT MEMBER STATES Cdmmunication from the Commission to the Council 1. On 17 January 1984, Vice-president TUGENDHAT sent to the Council a communication (1) which stressed the need to establish without delay the tax conditions for increased cooperation between undertakings across intra-Community frontiers and, to that end, to adopt, the following three proposals for directives - the common ~ax arrangements applicable to mergers, divisions and contribution of assets occurring between companies of different Member States ; the common tax arrangements applicable to parent companies and subsidiaries of different Member States ; - the elimination of double taxation in the case of adjustment of profits between associated enterprises (a;bitration procedure). At its meeting on 12 March 1984, the Council agreed that priority should be given to the examination of these proposals and requested the Permanent Repr~sentatives Committee to report to it before 31 May 1984. 2. The active examination by COREPER has enabled agreement to be reached on all the main provisions of th~ three texts with the exception of four points, which were submitted for a decision to the Council at its meeting on 4 June 1984 (2). These points concern : .1. (1) Doc. SEC(84)77 (2) Doc. 7444/84 FISC 53 of 26 May 198~. , ... 2.- 1) the problem raised, in the framework of the "Mergers" directive, by the system of joint management applied in Germany ; 2) the inclusi

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