The article considers directions of harmonization in the area of direct taxation in the Eurasian Economic Union (EAEU). The article also examines the actions of the EAEU Member States on the implementation of the Base Erosion and Profit Shifting (BEPS) Action Plan in national tax legislation.
The author comes to the conclusion that the EAEU Treaty and other supranational acts show few limits of tax harmonization and mainly in the area of indirect taxation. In the area of direct taxation, the establishment of the principle of non-discrimination and convergence in the area of taxation of personal income are elements of harmonization in the area of direct taxation. At the national level, Member States have set the same taxes, including corporate income tax and personal income tax. However, in the absence of supranational acts of secondary law, national tax systems differ significantly. This is caused by the fact that the area of direct taxation is highly sensitive from the positions of tax sovereignty of Member States.
The important part of the survey is the comparative study. The European Union (EU) has become the most comprehensive form of interstate integration. However, financial and political crises in Europe have shown the need to give up some of the sovereign rights of Member States in order to ensure a coherent policy. The European experience is of great theoretical and practical importance for creating new legal mechanisms of tax regulation in the EAEU. The models of functioning of the EAEU Court and of the European Court of Justice (ECJ) in the area of taxation are also compared in the article.Intertax