Schriftenreihe zum Internationalen Steuerrecht

This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021.

This volume provides an in-depth analysis of various aspects of tax and technology. The book is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law.

This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of the specific aspects of “Multilateral Cooperation in Tax“. The chapters focus on an analysis with regard to possibilities for improvement and an outlook on future development opportunities.

This publication covers various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19.

This book provides guidance on the meaning of territoriality in the CJEU’s case law on direct taxation as well as on the role which this principle plays in the compatibility of domestic direct tax measures with the fundamental freedoms. It contains references to more than 300 cases.

This book analyses selected topics (e.g. taxpayer rights in EU VAT law, bad debt and insolvency in VAT law, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the CJEU. Experts from all over the world have provided their input.

“Justice, Equality and Tax Law” is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. This volume represents an in-depth analysis of various aspects of this evergreen topic.

This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and secondary EU law are analyzed. The analyses are presented by esteemed national and European tax law experts.

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020.

This book analyses selected topics (e.g. fundamental principles and VAT, VAT treatment of financial services, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the CJEU. Experts from all over the world have provided their input.

This book discusses the most important issues and recent developments related to transfer pricing and financial transactions. It contains an analysis on the delineation of financial transactions and deals with the specific transactions concerning loans, financial guarantees, and cash pooling.

This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and secondary EU law are analyzed. The analyses are presented by esteemed national and European tax law experts.

This volume provides a rigorous analysis of various aspects related to treaty access. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis.

This volume provides an in-depth analysis of various aspects of CFC legislation. It analyses different approaches to successfully address base erosion and profit shifting through the use of CFC legislation and provides practical guidance for the effective implementation and application of CFC rules.

This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019.

This book analyzes selected topics (e.g. fundamental principles and VAT, administrative cooperation in VAT, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the CJEU. Experts from all over the world have provided their input.

This volume provides an in-depth analysis of various aspects of hybrid entities in tax treaty law. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities.

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 41 most important tax treaty cases which were decided in 2018 around the world.

This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and secondary EU law are analyzed. The analyses are presented by esteemed national and European tax law experts.

Dieses Buch befasst sich mit den für die Ergebnisabgrenzung in multinationalen Unternehmensgruppen entscheidenden Aspekten. Es enthält ua eine dogmatische und politische Analyse der Auslegung des Fremdvergleichsgrundsatzes und eine Analyse der Ergebnisabgrenzungsbestimmungen im OECD-Musterabkommen.

This book presents the most important issues and recent developments related to the attribution of profits to permanent establishments. It contains the opinions of representatives of tax administrations, multinationals and tax advisories.

With focus on the unique features of the UN Model Convention, this book is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.

Value Creation and its effects on Transfer Pricing and tax law

Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse ...

This book analyzes selected topics (e.g. the Charter of Fundamental Rights of the European Union and VAT, taxable base and rates, exemptions and deductions) by examining the most prominent and recent judgments of the CJEU. Experts from all over the world have provided their input.