论欧盟所得税协调机制——兼论对我国的借鉴意义

The EU Income Tax Coordination Mechanism and Its Implication for China

欧盟成员国所得税法所导致的双重征税和税收歧视阻碍了内部市场的自由流动。欧盟进行了协调成员国所得税制的尝试,拓展了税收非歧视待遇的适用范围。但是,在成员国享有税收主权的前提下,欧盟现行协调机制仍无法彻底解决双重征税和税收歧视。欧盟的实践也能够为我国消除区域经济合作中的所得税壁垒提供借鉴。

Double taxation and tax discrimination caused by income tax systems of Member States of the EU have resulted in the barriers on the free movement in the internal market. Consequently, EU has coordinated the income tax systems of its Member States and extended the scope of application of non - discrimination principle in the field of taxation. However, the current coordination mechanism still can not thoroughly solve the problems of double taxation and tax discrimination because of tax sovereignty enjoyed by Member States. Nevertheless, the practice of EU may be of reference value to China in eliminating income tax barriers in regional economic cooperation.