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This article presents a preliminary legal evaluation of the proposed Council Directive on transfer pricing in the European Union. The authors express their appreciation for the European Commission’s ambitious initiative, which seeks to address disparities and distortions in tax competition across national legislation. However, they identify areas where improvement is needed to promote legal and tax certainty and simplify compliance, thereby enhancing the effectiveness of the proposed Directive. Consequently, the authors suggest further work in specific areas to achieve the objective of positive integration.
Pistone et al. (Fri,) studied this question.