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Taxation and Customs Union

Double taxation Conventions

Double Tax Conventions (DTCs) are bilateral agreements between two states, primarily aimed at avoiding double taxation of income or capital. 

Double taxation Conventions

Double Tax Conventions (DTCs) are bilateral agreements between two states, primarily aimed at avoiding double taxation of income or capital. According to the OECD Model Tax Convention, their purpose is to promote cross-border trade and investment. They allocate taxing rights between contracting states in a way that prevents the same income from being taxed twice, while also combatting tax evasion and avoidance. Although Member States retain the power to conclude DTCs, the Court of Justice of the European Union (CJEU) has consistently ruled that DTCs between EU Member States must always comply with EU law.

Recent developments

Recent developments in the Union include the termination of a few long-standing DTCs. In such cases, the outcome is that the relevant income flows are governed by domestic tax laws. The following DTCs between Member States have been terminated by one party without new agreement in place: Denmark and Spain, Finland and Portugal, as well as Sweden with both Portugal and Greece. 

In other instances, new or revised treaties have been signed but are still awaiting ratification before entering into force. One recent example is the updated tax treaty between Cyprus and France, signed in December 2023. While Cyprus has ratified the agreement, this is pending approval in France.

Contact information

For the most accurate and up-to-date information on tax treaties and related issues, taxpayers should consult the official websites of national tax authorities. 

Contact information for national tax administrations of EU countries

These sites provide access to treaty texts, legislative updates, and in case, practical guidance for navigating cross-border tax situations: