• Contents 1. Executive summary
  • 1.1. The question to be addressed
  • 1.2. Executive summary
  • 2. About this document
  • 2.1. The background and general objectives of the study
  • 2.2. Description of work performed
  • 3. The parameters of the study
  • 3.1. What kind of specific tax regime?
  • 3.2. The temporary nature of a pilot project
  • 3.3. Participation in the specific tax regime u0096 a possibility or a requirement?
  • 3.4. What does this study compare?
  • 3.5. Fundamental rights and non-discrimination principles
  • 3.6. What is meant by legal problems for the setting up of a specific tax regime?
  • 4. EC Treaty state aid rules
  • 4.1. The field of study
  • 4.2. Articles 87, 88 and 89 EC u0096 the state aid rules
  • 4.3. The conditions for state aid
  • 4.4. Compatibility with the Common Market
  • 4.5. Conclusion
  • 5. EU commitments to the WTO
  • 5.1. The field of study
  • 5.2. The EUu0092s binding agreement with the WTO
  • 5.3. Would income tax legislation for the SE be a generally applicable tax measure outside the scope of the WTO Agreement?
  • 5.4. EU commitments on non-discrimination in the WTO
  • 5.5. Commitments on subsidies in the WTO
  • 5.6. Whether the dispute resolution procedure gives rise to negotiations or a right of compensation
  • 5.7. Whether the EU commitments have direct effect in the EC
  • 5.8. Whether a specific tax project for the SE that conflicts with the WTO Agreement would give rise to legal consequences
  • 5.9. Process for raising potential discrimination or subsidy issues with the WTO
  • 5.10. Conclusion
  • 6. Discrimination between legal forms and between businesses
  • 6.1. The field of study
  • 6.2. Interpreting the questions
  • 6.3. Different tax treatment of domestic legal forms and the SE
  • 6.4. Different tax treatment of domestic and international companies
  • 6.5. Conclusion
  • 7. Enhanced cooperation
  • 7.1. The field of study
  • 7.2. The relevant treaty provisions
  • 7.3. Interpretation of A