Towards a European Union Federal Tax System: Legal and Fiscal Perspective. An International Comparison

Abstract

This paper offers a comprehensive and rigorous analysis of the feasibility of establishing a European federal treasury from a legal, institutional and comparative perspective. Based on a study of established federal tax systems, such as those in the United States of America, Germany and Switzerland, it identifies the structural elements necessary for the EU to develop its own tax structure: direct taxing power, a significant budget, borrowing capacity and effective mechanisms for redistribution and stabilization. The analysis is complemented by an examination of the EU’s legal framework, the limitations imposed by the Treaties and the case law of the German Federal Constitutional Court. Finally, recent proposals for tax reform aimed at introducing new own resources and institutionalizing the issuance of common debt are evaluated. The central thesis argues that a European federal treasury is not only desirable but essential to safeguard the EU’s strategic sovereignty, internal cohesion and capacity to act at the global level.