The Commission is currently considering closely the possible conflicts between the EC Treaty and the bilateral double taxation treaties that Member States have concluded with each other and with third countries.
The EU Joint Transfer Pricing Forum (JTPF) assists and advises the European Commission on transfer pricing tax matters.
The objective of the Merger Directive is to remove fiscal obstacles to cross-border reorganisations involving companies situated in two or more Member States.
On 22 December 2003, the Council adopted Directive 2003/123/EC to broaden the scope and improve the operation of the Council Directive 90/435/EEC on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States.
New rules on tax dispute resolution apply since 1 July 2019. They are laid down in Council Directive 2017/1852 of 10 October 2017 and bring a significant improvement to resolving tax disputes.
The fight against corporate tax avoidance is central to the European Commission's political priority to ensure a fairer Single Market. It is closely linked to the agenda to tackle tax fraud and evasion.
In order to provide for a comprehensive framework of anti-abuse measures the Commission presented its proposal on 25th October 2016, to complement the existing rule on hybrid mismatches. The rule on hybrid mismatches aims to prevent companies from exploiting national mismatches to avoid taxation.