European Commission: consultation on double non-taxation cases.

May 30, 2012

On May 30, 2012, Tax Executives Institute filed the following comments with the European Commission addressing the EC's public consultation paper regarding "The Internal Market: Request for contributions on factual examples and possible ways to tackle double non-taxation cases," as published on the EC's website on February 29, 2012. TEI's comments focus on items of general concern rather than factual examples of double non-taxation, including the need for the EC to address not only cases of double non-taxation, but also instances of double taxation. The comments were prepared under the aegis of TEI's European Direct Tax Committee, whose chair is Anna Theeuwes of Shell International B.V. Benjamin R. Shreck, TEI Tax Counsel, acts as staff liaison to the European Direct Tax Committee and coordinated the preparation of the comments.

On behalf of Tax Executives Institute, Inc., I am writing in response to the European Commission's public consultation regarding double non-taxation, as published on the Commission's website.

Tax Executives Institute (TEI) was founded in 1944 to serve the needs of in-house tax professionals. Today, the organisation has 55 chapters around the world, including one in Europe. As the preeminent association of in-house tax professionals worldwide, TEI has a significant interest in promoting fair tax policy at all levels of government. Our nearly 7,000 members represent 3,000 of the largest companies in Europe, the United States, Canada, and Asia. The Institute is included in the EU Interest Representative Register (Register ID number 52413445902-12; TEI's address is 1200 G Street, N.W., Suite 300, Washington, D.C., U.S.A., 20005-3814).

TEI members are responsible for planning and managing the tax affairs of their employers. Therefore the organisation is dedicated to the development of sound tax policy, compliance with and uniform enforcement of tax laws, and minimisation of administration and compliance costs to the benefit of both government and taxpayers.

These goals can be attained only through members' voluntary actions and their adherence to the highest standards of professional competence and integrity.

We welcome the opportunity to comment on the European Commission's consultation on "The internal market: factual examples of double non-taxation cases," published 29 February 2012 (Consultation), to gather evidence of double non-taxation within the EU and with Third Countries, with the aim of...