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由于基础条约授权不同,欧盟在关税、间接税和直接税领域采取了不同的介入机制,造成了这三个领域的一体化程度不一,而且直接税领域成为一体化的瓶颈。从2013年开始,欧盟利用参与BEPS项目的契机,颁布了多项软法措施来指导成员国如何打击跨国公司的避税行为,并且在2016年6月成功通过了《反避税指令》,规定了成员国制定反避税措施时必须遵循的原则,削弱了成员国在直接税领域的税收主权,将欧洲税收一体化进程向前推动了一大步。虽然之后的英国“脱欧”公投给欧洲一体化走向蒙上了一层迷雾,但在税收领域,各成员国在增加财政收入、打击逃避税和争取国际规则制定权等问题上的共同利益并未改变,所以欧盟仍有机会继续利用BEPS项目来推进欧洲税收一体化。
Due to the different authorizations of the basic treaty, the EU adopted different mechanisms of intervention in the areas of tariffs, indirect taxes and direct taxes, resulting in different levels of integration in these three fields and the direct tax area has become the bottleneck of integration. Starting from 2013, the EU took advantage of its participation in the BEPS project and issued a number of soft law measures to guide member countries in how to combat the tax avoidance behavior of multinational corporations. In June 2016, the EU successfully passed the Anti-Tax Avoidance Directive and stipulated that members The principle that countries must follow when they formulate anti-avoidance measures has weakened the tax sovereignty of the member states in the area of direct tax and has taken the European taxation integration a big step forward. Although the ensuing British “Brexit” referendum has cast a foggy fog over the integration of Europe, in the field of taxation, all member states have jointly raised the issue of increasing revenue, cracking down tax evasion, and striving for the formulation of international rules. The benefits have not changed, so the EU still has the opportunity to continue using the BEPS project to promote European taxation.