European Tax Law and International Tax Law

Philippe Marchessou


The present article, before analysing the relationship between international tax law and European tax law, first of all wonders whether or not an international tax law even exists, as a complex of common principles justifying the allocation of taxing powers amongst States in a cross-border context, and, in case of positive answer, which are its fundamental components. Secondly, with reference to European tax law, whose existence is irrefutable, attention will be paid to outlining its contours, with regards both to positive law defining tax regimes in all harmonised sectors in light of the Union’s purposes and to the role of the Court of Justice, as protector of the fundamental Treaty freedoms in the field of direct taxation as well.


European Tax Law; International Tax Law; double taxation conventions; European Union; OECD Model; sovereignty; harmonization; discrimination; fundamental freedoms

DOI: 10.6092/issn.2036-3583/5584


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