Tax Discrimination and Capital Neutrality

Abstract

States use their tax systems to influence inbound and outbound investment, but the non-discrimination article of the OECD Model limits states’ ability to apply tax preferences for resident investors over non-resident investors. This paper attempts to lay out the tax policy issues underlying the non-discrimination article, and to do this, it will give background on the traditional capital neutrality benchmarks – namely, capital export neutrality (CEN) and capital import neutrality (CIN). The specific questions framed by the seminar organizers make reference to the non-discrimination principle under EC law, so the paper will also compare the OECD Model non-discrimination principle with that of the EC Treaty.

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