CentER

Daniël Smit

Date of PhD defense:	2 December 2011
Title of thesis:	Freedom of Investment between EU and non-EU Member States and its impact on corporate income tax systems within the European Union
ISBN:	978 90 5668 303 0
Promotor:	Prof.dr. Eric Kemmeren

Abstract:

The world economy today is characterized by a high degree of international economic integration. This is evidenced not only by a large global network of international trade and investment agreements, but also by daily practice in which international trade and investment are widespread. Practice shows that the EU Member States maintain a diversified range of economic relations with non-EU Member States. It is this unique relationship between the EU Member States and the rest of the world which this study takes as a starting point. It focuses on freedom of investment between Member States and non-EU Member States under European law and its impact on the Member States’ corporate income tax systems. This study essentially seeks to examine the extent to which the impact of freedom of investment on Member States’ company income tax systems is similar in the relations between Member States and non-EU Member States compared to the relations between Member States. Based on the benchmark of international tax neutrality, it subsequently evaluates the extent to which company income tax measures applied by Member States and affecting patterns of investment between Member States and non-EU Member States should be removed. With reference to a number of selected company income tax measures it demonstrates how this could be realized.