In Chapter 1, the inherent limitations in the powers of the EU institutions to enact legislation in the field of direct taxes were discussed. The lack of Union competence in this area and the sensitivity of Member States to any attempts for harmonisation were identified as the main reasons for the scarce legislation. Chapter 1 also considered the historical background to some of the legislative proposals for the removal of tax obstacles in the cross-border movement of companies.Proposals for harmonisation were followed by proposals for coordination and ad hoc targeted measures. These led to piecemeal legislative solutions and soft law. It was explained how with the advent of the BEPS project, the Commission produced various legislative proposals, most of which were very protective of Member State tax bases. The soft law initiatives also proved very important, as they laid the ground for the creation of a common external fiscal policy, even in the absence of a common internal fiscal policy. This has proven to be a springboard for further developments, as shown from recent developments and the Brexit discourse.