The master thesis examines the development of EU tax policy in the field of direct taxation of businesses. It bases its analysis on the Communication from the European Commission to the European Parliament and the Council: Business Taxation for the 21st Century, which presents the EU's vision in this area. At the core of the Communication are four proposals for directives, namely UNSHELL, DEBRA, Pillar 2, and BEFIT, which are presented and evaluated, as this is the best way to illustrate the evolution of tax policy in the EU. This is an interesting area as traditional concepts of international tax law are no longer adequate to the challenges of the modern economy, which is characterised by globalisation and digitalisation. In addition, the EU has extremely limited competence to act since it can only adopt directives if they are unanimously approved by the Council, which effectively means that the Member States have a veto. The latter means that Member States have to make political compromises in order to reach unanimity. Of the four directives put forward, only Pillar 2 was adopted, hence the thesis analyses the decisive factor responsible for the success of this particular proposal. The thesis concludes that both substantive refinement and the political will of all Member States are necessary. UNSHELL and DEBRA are substantively lacking, while there was no political will for BEFIT and Pillar 2, nevertheless, the latter was still adopted. The Pillar 2 Directive is based on an international Two-Pillar solution under OECD/G20 BEPS, which reflects US national interests. The thesis concludes that unanimity was not the result of free will of all EU Member States, but was achieved due to political pressure from the US on Member States that would otherwise not support the proposal.
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