The Commission Proposal for a Directive on Double Taxation Dispute Resolution Mechanisms: Will it resolve the remaining double taxation issues within the EU?

Abstract: Double taxation has been widely accepted that constitutes an obstacle to the functioning of the single market. The European Union has adopted some uniform measures to have double taxation eliminated, for example, the Parent-Subsidiary Directive and the Interest-Royalty Directive. In addition, the Arbitration Convention has been concluded between Member States to eliminate double taxation in respect of transfer pricing adjustments. However, they all have limited scope and are unable to provide broad protection to the taxpayers. To improve the existing double taxation resolution mechanism, the European Commission proposed a directive in October 2016. This thesis aims to identify the remaining double taxation issues which cannot be resolved by the current EU legislation and to find out whether the Proposed Directive will provide a resolution to these issues.