Commission[3] (“EC”). In 2016, the EC’s Joint Research Centre calculated the

annual cost of this issue to amount to EUR 8.4 billion in foregone tax relief, costs

or reclaim procedures and opportunity costs. Numerous vast research reports,

recommendations, and even implementation packages spelling out what

standardized and unified relief procedures should look like, have brought no

unification, or even harmonization, in this field to the EU whatsoever. Looking at

the latest communication from the EC, “Completing the capital markets union by

2019”, released on March 8, 2018, what stands out is that the withholding tax

barrier is not mentioned once. Instead, as far as taxes are concerned, the EC

focuses solely on the common consolidated corporate tax base, its new crown

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