Taxation of Capital Gains in European Union Member States. Comparative Analysis on the Example of Legal Regulations in France, Poland, and Sweden
Taxation of Capital Gains in European Union Member States. Comparative Analysis on the Example of Legal Regulations in France, Poland, and Sweden

Summary/Abstract: Capital gains taxation can be a crucial element of the competitiveness of a given economic area or country, especially from the perspective of investors operating at the level of international market. The purpose of this article, which utilizes a dogmatic, historical-descriptive, and primarily comparative method, is to compare and contrast models of capital gains taxation within the European Union. In particular, the scope of general EU regulations in this area will be analyzed, as well as certain national specificities, which will be demonstrated in French and Polish law, also with reference to the model adopted in Sweden. Therefore, a crucial issue will be to determine whether national solutions merely constitute modifications of the base model used in the EU or whether they are entirely different models based on the principle of diversification of legal solutions across the EU. A comparative analysis will allow for deeper conclusions in this area, including answering the question of whether a single European model of capital gains taxation is possible, or whether the differences at the level of individual countries are too significant. The diverse approaches to regulating capital gains taxation presented in this study may constitute an interesting element of further, in-depth analysis, extended to other countries and continents, aimed at finding the most optimal model adapted to contemporary economic realities. It is worth mentioning that this adaptation to economic realities should take into account the disruption of international stability due to successive crises and thus adhere more closely than before to the principle of legal certainty, which is crucial today.

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