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A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty ben...
As the struggle to combat tax abuse and tax avoidance gains momentum, ways of making a tax jurisdiction ‘manipulation-proof’ continue to proliferate, from new or revised provisions in model tax treaties to a dramatic increase in the number and variety of anti-abuse and anti-avoidance rules at all levels of government. These measures interact with national tax systems, general anti-abuse clauses and tax treaties. The conflicts and other legal difficulties that inevitably result deserve intensive scrutiny. This book provides an in-depth analysis of current issues concerning the relations of various anti-abuse rules to each other and their impact on the application of tax treaties. The topi...
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.
During the 1970s todays Austrian Federal Ministry of Education, Science and Research (Bundesministerium für Bildung, Wissenschaft und Forschung, BMBWF) supported the founding of the Center for Austrian Studies at the University of Minnesota in Minneapolis and the Austrian Chair at Stanford University in California. These foundings were the initial incentives for the worldwide `spreading' of similar institutions; currently, nine Centers for Austrian and Central European Studies exist in seven countries on three continents. The funding of the Ministry enables to connect senior scholars with young scholars, to help young PhD students, to participate in and to benefit from the scientific connec...
This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.
The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right f...
The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts ...
Series on International Taxation #81 The tax landscape today looks dramatically different from how it appeared even a generation ago. Ongoing sweeping changes in information technologies, massive economic downturns, unforeseen catastrophes such as the global pandemic that hit the world in 2020, and ever more sophisticated methods of tax evasion and avoidance are only some of the factors that have perplexed and even confounded tax authorities. This important book provides a comprehensive overview of the global tax challenges confronting tax policy today, with insightful contributions by both well-known tax experts and fresh new voices in the field. The authors address such critical issues as ...
Taxing Artificial Intelligence will be essential reading for scholars, policy makers and students across law and economics. It will also be invaluable for law and tax professionals seeking to understand the latest developments in AI, automation, and the future of work.