Abstract EN:

In the fight against tax avoidance, the goal pursued by the national policies of member states is ambiguous. And in the absence of a European tax convention, the bilateral tax conventions are instrumental in treaty shopping operations. The EU (European Union) could have been a better framework to devise measures against tax avoidance. However, since there is no political will to create a harmonized tax policy, the current orientation toward tax coordination is bound to prove much less useful in order to curtail tax avoidance. The tax competition between states is generally perceived as developing, either in the EU or outside. Thus the opportunities for tax avoidance stemming from such a trend will be more numerous, further incapacitating the ability of individual states to limit the phenomenon. In this highly competitive situation, the WTO (World Trade Organization) ruling on disloyal practice about the United States could provide a global base on which to build a global tax policy able to constrain the imagination of global actors.