Why this book?
Despite the EU internal market, income tax treaties concluded between the EU Member States are still bilateral. Only the Nordic countries (Denmark, the Faroe Islands, Finland, Iceland, Norway and Sweden) have concluded a multilateral income tax treaty. The treaty is one of the few multilateral income tax treaties existing worldwide, and it has functioned fairly well. It is based on the OECD Model Convention but modified to meet the needs of a multilateral treaty.
If the Nordic multilateral tax treaty would be modified to better comply with the requirements of EU law, it could provide a good model for a multilateral EU tax treaty covering all EU Member States. Such a multilateral EU tax treaty would abolish many of the obstacles caused by the unintegrated direct tax systems of the Member States to the functioning of the internal market.
This book first examines the requirements that EU tax law puts on a multilateral EU tax treaty and then studies the Nordic multilateral tax treaty, article by article, with the purpose of answering the question of how the Nordic treaty should be modified in order for it to function as a model for a multilateral EU tax treaty. The book is essential reading for those interested in the EU law issues related to tax treaties, as well as for anyone interested in the details of the Nordic multilateral tax treaty.
Marjaana Helminen (Doctor of Laws, University of Helsinki; Master of Arts, Economics, Turku School of Economics) is professor of international and comparative tax law at the University of Helsinki, Finland. She specializes in international and EU tax law and regularly lectures on tax treaties and EU tax law at universities and tax conferences. Professor Helminen previously worked as a tax adviser for Loyens & Loeff in Amsterdam and as a justice in the Supreme Administrative Court of Finland. In 2000, she won the Mitchell B. Carroll Prize (International Fiscal Association) for her doctoral thesis “The Dividend Concept in International Tax Law – Dividend Payments between Corporate Entities”.