European Union/International - Non-Discrimination Provisions at the Intersection of EC and International Tax Law
- European Union/International
- Bruno Santiago
- European Taxation, 2009 (Volume 49), No 5
- 1 May 2009
The purpose of this article is to propose the basis for what could be a future nondiscrimination provision in an EU Model Treaty or a Multilateral Double Taxation Convention entered into between the Member States. In this respect, the author focuses on the concept of non-discrimination, notably the similarity test required, and attempts to find reasonable and identified criteria to deal with this concept.