TAX INTEGRATION IN THE AREA OF DIRECT TAXATION IN THE EUROPEAN UNION

The article is devoted to analysis of tax harmonization in the area of direct taxation in the European Union. Issues of positive and negative integration, common market and tax harmonization are analyzed. The author mentions the following benchmarks of the European tax integration: tax harmonization in the area of direct taxation, prohibition of discrimination and unfair competition, leading role of fundamental freedoms in the field of European integration. The development of the tax law of integration associations is conditioned by the dualism of direct and indirect taxes. It is not only rooted in the tax systems of the Member States, but is also reflected in the constituent treaties. Despite the conventionality, the division of taxes into direct and indirect ones is of fundamental importance: the ratio of direct and indirect taxes is the most important structural indicator of the tax system. The special role of the European Court of Justice in forming EU tax law is emphasized. The current developments of the EU tax law in connection with realization of OECD BEPS Action Plan are brought into light. The author concludes that the main reason of the leading role of the negative integration is the requirement for unanimous adoption of decisions on tax issues and the perception by Member States of their tax sovereignty against the backdrop of the "lack of tax authority" of the Union.