• Profili giuridici del coordinamento tra sistemi reddituali nell'Unione Europea
  • Income tax systems' co-ordination in the European Union
  • Marzano, Michele <1981>


  • IUS/12 Diritto tributario


  • Il coordinamento tra sistemi impositivi è una questione originaria e tipica del diritto comunitario. La tesi ne esplora le conseguenze sotto più aspetti.
  • Income tax systems' co-ordination is a relatively recent issue in the globalizing economy. In fact, a tendence to tax co-ordination begins, essentially, with the EU Law. Since 2006, European Institutions feel the urgence to solve problem of double imposition and non imposition phenomena left unsolved by the member states themselves, or by means of Double Taxation Conventions (DTCs). The tax co-ordination envisages means to do so. The theme is firstly envisaged by the unilateral and bilateral perspective, underlining the deficiencies of sovereignity methods in fronting the economies' integration problems. The theme is then pointed out by the perspective of EU Law. At a first level, by considering tax systems co-ordination methods envisaged by the Directives in matter of group-taxation. Then, monitoring the outgoing of co-ordination considered by three EU Communications dated 19 December 2006 (respectively targeted to the general problem of tax co-ordination, to the co-ordination between member states upon exit taxation, to the co-ordination upon consideraton of intra-EU losses). The issue is also considered by the point of view of the European Court of Justice. In this perspective, it's relevant to estabilish whether the ECJ has the power to compel the member states to structure each other their income tax systems, based on the application of the EU freedoms, with a view – in particular – to exit taxation policies, to intra-EU losses: a theme strictly linked to the view that is optioned out for the interpretation of EU non-discrimination clause (an overall approach facing the opposite per-country approach).


  • 2012-12-12


  • Doctoral Thesis
  • PeerReviewed


  • application/pdf



Marzano, Michele (2012) Profili giuridici del coordinamento tra sistemi reddituali nell'Unione Europea, [Dissertation thesis], Alma Mater Studiorum Università di Bologna. Dottorato di ricerca in Diritto tributario europeo , 23 Ciclo. DOI 10.6092/unibo/amsdottorato/5125.