L'harmonisation de la fiscalité des revenus du capital en Europe : pragmatisme ou dogmatisme ?

This paper reexamines tax harmonization and tax competition in the European Union. Clumsily justified by the threat of huge capital movements, their enforcement would de facto lead to the establishment of an european withholding tax, which is, per se, completely inconsistent with the characteristic erga omnes of the liberalization. Only the adoption of a tax principle, consisting in a redefinition of tax frontiers and States? ability to impose residents and non residents, could insure the respect of efficiency, neutrality of the national tax systems and equity among taxpayers. Moreover, such an agreement doesn?t require any harmonization of tax rates. Tax harmonization, whatever form it takes, becomes useless and redundant, because it also requires the initial stage of renegociation of States? sovereignties.