Die Zinsbesteuerung in der Europäischen Union

Considering the extent to which progress is being made with the integration of the European Capital Market, harmonisation of the taxation of income is becoming increasingly important. Efficient allocation of capital must not be hindered by inter-governmental tax differentials. Following more than forty years of discussion, the approach that is now beginning to emerge is one by which the principle of country of residence is translated into reality via a system of information exchange and tax collected at source. The information model should guarantee that interest income earned abroad is declared in the taxpayer's country of residence. EU states that place great value on banking secrecy should be able to charge tax collected at source for interest income earned there during a transition phase ending in 2002. Their tax rates must be raised from 15 % to 35 % during this period in order to stimulate the transition to information exchange in these countries as well. In this context, Switzerland and other third countries, which are supposed to give up their status as tax havens and adopt this approach, represent a particular problem relating to tax policy. The model chosen for the EU is a pragmatic concession in so far as its intervention in national tax law is relatively limited. With its interest income tax rate of 25 %, which is to apply to interest income earned by resident taxpayers from 2004 onwards, German tax legislation has opted for an approach that would be compatible with the European solution if, while implementing the European approach, information about interest income earned in Germany by non-resident individuals could also be passed on. Both the standards negotiated for a European guideline on the taxation of interest income and the German approach are incomplete in as far as there remain considerable gaps in the recording of impersonal and personal tax liability. Further efforts need to be made as regards tax policy in order to eliminate the remaining deficiencies in the taxation of interest income and bring about coordination between the burden of interest income and the likewise necessary harmonisation of corporate management in a way that makes sense economically.