Tax Treaties and the EC Law

The laws of the member states of the European Union (EU) and the tax treaties they conclude must be consistent with European Community (EC) law. As a result, the EC Treaty may effectively alter the content of tax treaties. This is of crucial importance to international tax planning techniques. Apart from EC Directives and Regulations, the EC Treaty itself contains rules directly applicable to matters of international taxation. In this context, the decisions of the European Court of Justice (ECJ) on the fundamental freedoms laid down in the EC Treaty are of primary importance. If a provision of a tax treaty conflicts with the EC Treaty, the Treaty supersedes it. This collection of essays examines the far-reaching effects of primary EC law, i

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Tax Treaties and the EC Law

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