Abstract: The European Union’s (EU’s) path of integration sees it adopt harmonising agendas in many areas of EU law. As they touch on areas of Member State sovereignty, these agendas are proving diffi cult to achieve, either without signifi cant reform, or at all. As a consequence, the future development of EU law in the direction of continued integration is not certain. Differentiated integration may be the viable alternative. The research question this article therefore seeks to answer is: How far should harmonisation go in the EU? In answering this question, the adoption of a case study methodology allows for generalising from a specifi c example to the wider EU trajectory. Tax embodies the tensions between Member State sovereignty and EU law harmonising agendas, and in the context of the imperative to harmonise caused by the digitalisation of the economy, it is a microcosm. The tax microcosm demonstrates that there are limits to how far harmonisation can go in the EU, and that the future will likely see more differentiated integration.
Keywords: digital tax; digital services tax; tax harmonisation; EU integration; differentiated integration
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