The EU and Third Countries : Direct Taxation - South Africa

This book chapter is part of an analysis of European Community (EC) law as it may apply to taxpayers who are resident or nationals of countries that are not EC members (third states), specifically in the field of tax law. The chapter addresses the relation between South African and EC tax law. The Treaty establishing the European Community (EC Treaty) does not make specific provision for the alignment or hamonisation of direct taxation. The situation is somewhat different when direct taxation has an impact on the four freedoms enshrined in the EC Treaty (free movement of goods, persons, services and capital) and the right of establishment of persons and businesses. National taxation systems must respect these four fundamental freedoms, including as they may apply to relations with third states