Introduction to European Tax Law on Direct Taxation

S. VPreface 7^th edition

During the past two years the EU Commission has been active in relaunching positive integration of direct taxes along two main axes, namely mutual assistance and the fight against BEPS. The latter development confirms a trend already visible during the earlier years, namely that international tax coordination under the auspices of the OECD has turned into the indirect engine of positive integration in the European Union.

The failure to reach consensus in the June 2022 Ecofin on the introduction of the global corporate minimum tax proposed directive confirms the extreme difficulties that arise in connection with the unanimity requirement for introducing secondary law of the European Union. The fact that this occurs even in areas on which this is highly desirable and generally accepted leads to wonder whether the tax veto is being still used for reasons that are connected with critical issues affecting national tax sovereignty of EU Member States. The paradox is that some EU Member States raise such issues ein the European Union, but not in the framework of global fora of international tax coordination.

The flipside of the persistent crisis in the issuing of secondar...