Zasada neutralności opodatkowania transgranicznych dochodów kapitałowych w prawie europejskim oraz krajowych przepisach prawa podatkowego wybranych państw członkowskich Unii Europejskiej

Conceptual pattern developed by P. Musgrave serves as methodological basis for critical assessment of two distinct approaches to tax neutrality, i.e., capital export (CEN) and capital import (CIN) neutrality. Furthermore, alternative stances on the above concept of neutrality of income taxation as proposed by Desai and Hines (elaborating on a previous work of Devereux), are subject to verification based on their applicability in the current framework of international tax law.Since the beginning of the 1970s, tax neutrality of cross-border income has been considered the basic tool for assessing the economic efficiency of international tax law standards. The thesis examines the principle of tax neutrality of cross-border capital income in the doctrinal dimension, showing its sources in nineteenth-century income-tax theory and the mature form in the contemporary achievements of public finance theoreticians