Reference : EU-US Relations in the Field of Direct Taxes from the EU Perspective: A BEPS-induced ...
Parts of books : Contribution to collective works
Law, criminology & political science : Tax law
Law, criminology & political science : European & international law
Law / European Law
http://hdl.handle.net/10993/35535
EU-US Relations in the Field of Direct Taxes from the EU Perspective: A BEPS-induced Transformation?
English
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
Apr-2018
The Implementation of Anti-BEPS Rules in the EU: A Comprehensive Study
Pistone, Pasquale
Weber, Dennis
IBFD
37-61
Yes
978-90-8722-446-2
Amsterdam
The Netherlands
[en] EU-US Relations ; ATAD ; EU tax competence ; EU external competence ; State Aid ; Tax aid
[en] This chapter attempts to cover a range of interrelated questions that are all inextricably linked to the EU-US relationship in direct tax matters. Its main theme is the potential influence of legal and political developments within the EU on this external relationship. Shining a critical light on the legality of some of the recent changes made to EU legislation and enforcement in the context of the global fight against BEPS, it argues that the US government's newly assumed active role with respect to EU tax policy may inadvertently strengthen tendencies to bring direct tax matters more comprehensively into the range of power of the Commission – including at the international level – as it creates an interest on the US side to negotiate directly with the 'rela decision makers' rather than intermediaries without sovereign power over the entirety of the issues. It concludes, however, that in the current state of integration of direct taxation within the EU, such a bilateral relationship and the conclusion of an EU-US DTA is not yet legally possible. This would likely change, however, if the EU were to adopt a comprehensive corporate taxation regime along the lines of the Commission's CCTB proposal. At the same time, the Commission can no longer be kept entirely on the sidelines in Member States' DTC negotiations.
Researchers ; Professionals ; Students ; General public
http://hdl.handle.net/10993/35535

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