The Process of Corporate Tax Harmonisation in the EC


1. Introduction: The legal basis and justification of EC measures regarding company law and direct taxation

1.1. Treaty limits on direct taxation

1.2. The Single European Act1.3. Legislative means and the role of the legislative bodies

1.4. Treaty Basis

Figure I. Table of enabling treaty provisions

1.5. Legal basis of the Merger and Parent-subsidiary Directives

1.6. Legal basis and instrument of the Arbitration Convention

1.7. EC company law

2. The economic justification of tax harmonisation in the EC

2.1. The Internal Market concept

2.2. The case for corporate tax harmonisation

2.3. Inadequate models of fiscal integration

2.4. The concept of tax harmonisation: definitions

2.5. The desirable characteristics of harmonisation

2.6. The desirable level of harmonisation

Figure II. Levels of fiscal harmonisation

3. Progress in harmonisation of corporate taxation

3.1. The Neumark Committee

3.2. Commission memorandum of 26 June 1967

3.3. Commission memorandum of March 1969

3.4. The Commissions 1975 action programme and progress up to 1990

3.5. The 1990 Package of three

3.6. The Ruding Committee

3.7. Commission guidelines and strategy

3.8. Mutual assistance between tax authorities

3.9. Non-discrimination and the ECJ

4. Why several of the Commissions proposals failed