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Suggestions of tax bases consolidation and subsequent apportionment among member states, as those issued by the European Commission, create a single market without tax obstacles identified to four neutralities, only if they ally tax bases harmonisation with tax rates harmonisation and decision for common apportionment criteria among member states. If not, opportunities remain for strategic production and distribution location, tax competition and transfer prices manipulations if value added is the apportionment criterion. The paper also investigates inclusion and exclusion of entities in or from the consolidation perimeter, as well as effects of the EU Commission suggestions on Non-European mne.Classification JEL: H32, H73, H87