Traduction de «Accordo sulla doppia imposizione fiscale » (Italien → Anglais) :

Calls on the Member States to work actively in line with the Commission’s Communication and recommendations by taking coordinated and determined EU action against tax fraud, tax evasion, tax avoidance, aggressive tax planning and tax havens, thereby guaranteeing a fairer distribution of the fiscal effort and increased tax revenues; urges the Member States to swiftly implement, among the many specific measures to be taken in this context, the Commission proposals for the introduction of a General Anti-Abuse Rule to counteract aggressive tax planning practices and for the inclusion of a clause in their respective double taxation conventio ...[+++]ns to prevent occurrences of double non-taxation;

The Communication on "Double taxation in the Single Market", of 11 November 2011[86], highlighted the main double taxation problems within the EU and concrete measures that the Commission will propose to Member States to address them, such as the establishment of a forum on double taxation and the adoption by Member States of a code of conduct and a dispute resolution mechanism.

Specifically, Member States are encouraged to include a clause in Double Tax Conventions (DTCs) concluded with other EU Member States and with third countries to resolve a specifically identified type of double non-taxation.

At the time the PSD was adopted, cross-border groups were generally at a disadvantage in comparison to domestic groups because of the double taxation to which profit distributions were subject; otherwise, bilateral double tax conventions were insufficient to create within the EU conditions analogous to those of an internal market.

– Promote good governance in tax matters and support fight against tax evasion through international standards, cooperation to facilitate the conclusion and implementation of agreements such as Tax Information Exchange Agreements and, where appropriate, Double Taxation Conventions, adoption and implementation of the OECD transfer pricing guidelines in developing countries and ongoing research on country-by-country reporting standard for multi-national corporations.

As an additional point, the Authority refers to the comments of the Norwegian Standing Committee on Co-operative Affairs and the observation that a tax exemption for cooperatives could be justified on the basis of double taxation arguments and accordingly fall within the nature and logic of the corporate tax system.