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Lue Hirnnekeno, Profess~r the University of Antwerp at Community legslation has been far from a success in the field of direct taxation. The Commission's 'Verona Paper' examines the negative balance of drect and indrect tax harmonization: 18 proposals are presently on the Council's table (perhaps a more accurate description would be that they are in its ice-box),and no less than 30 proposals have been withdrawn by the Commission. The 1975 action urozramme outlined some initia" tives to combat international tax evasion and avoidance with two concrete measures: the 1975 Proposal on harmonization of tax systems (withdrawn) and the 1977 Directive on Mutual Assistance (hardly the right start for an action programme of a Community designed principally for the benefit of enterprises, not of tax authorities) which up to now has been of little benefit beyond the application of bilateral treaties. The 1990 Directive on Mergers (effective since 1992) 1s today only partially implemented by some Member States. The Convention on Transfer Pricing Arbitration 11990) onlv became effective in 1995: and the national authorities are still in the process of kstablishing their commissions and their rules of conduct. The 1990 Directive on Parent Subsidiaries has been a success; but
EC Tax Review – Kluwer Law International
Published: Jun 1, 1996
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