Activities of Michael THEURER related to 2016/0338(CNS)
Plenary speeches (2)
Double taxation dispute resolution mechanisms in the EU (debate) DE
Double taxation dispute resolution mechanisms in the EU (debate) DE
Reports (1)
REPORT on the proposal for a Council directive on Double Taxation Dispute Resolution Mechanisms in the European Union PDF (708 KB) DOC (114 KB)
Amendments (3)
Amendment 74 #
Proposal for a directive
Recital 7 a (new)
Recital 7 a (new)
(7 a) The scope of this Directive should be extended as soon as possible. The Directive only provides a framework for the resolution of disputes regarding the double taxation of business profits. Disputes on the double taxation of income (i.e. pensions, salaries) have not been brought under its scope, while the impact on individuals can be significant. A different interpretation of a tax agreement by Member States can lead to (economic) double taxation, for example if one Member State interprets a source of income as salary while the other Member State interprets the same source of income as profit. Therefore, interpretation differences in taxation of income between Member States should also be brought under the scope of this Directive.
Amendment 76 #
Proposal for a directive
Recital 7 b (new)
Recital 7 b (new)
(7 b) Currently, it is unclear how this Directive relates to existing arbitration provisions in bilateral tax agreements and the existing Union Arbitration Convention. Therefore, the Commission should clarify those relations so that taxpayers can, if applicable, choose the procedure best fit for purpose.
Amendment 77 #
Proposal for a directive
Recital 7 c (new)
Recital 7 c (new)
(7 c) A large number of double taxation cases involve third countries. Therefore, the Commission should strive to create a global framework, preferably within the context of the OECD. Until such OECD framework has been realised, the Commission should aim for a mandatory, instead of the current voluntary, and binding agreement procedure for all cases of potential cross- border double taxation.