The effect of Community law on pre-accession tax treaties

Dr Christiana HJI Panayi,BA, BCL (Oxon), PhD (LSE), Lecturer in Tax Law, Queen Mary, University of London1

The topic of the relationship between tax treaties and Community Law is already a difficult one for seasoned Community lawyers. The topic of the relationship of pre-accession tax treaties and Community law is arguably an even more difficult one, as it is closely intertwined with principles of international treaty law.2 In particular new Member States and candidate countries express the concern that there is no real guidance on the issue of pre-accession tax treaties.

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