Schriftenreihe zum Internationalen Steuerrecht

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.

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 35 most important tax treaty cases which were decided in 2017 around the world.

This book provides the most important issues and recent developments related to transfer pricing treatment of intangibles. Based on the outcomes of the WU Transfer Pricing Symposium it contains the opinions of representatives of tax administrations, multinationals and tax advisories.

Background information on tax arbitration, comparisons with other areas of law and recent developments: „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and shows how to enhance the framework of cross-border tax dispute resolution.

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.

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.

A Global Overview of International Tax Disputes on DTC

 

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 ...

Time to discuss anti-BEPS measures around digitalization

 

In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the ...

The most important and recent judgments of the CJEU

Considering the ever increasing importance of indirect taxation as a source of revenue for governments, the intensifying complexity of legal framework, and the proliferating number of countries adopting indirect ...

Von verstärkter Transparenz bis zum gläsernen Steuerpflichtigen

Wie geheim sollen Steuerdaten sein? Was ist durch das Verrechnungspreisdokumentationsgesetz zu beachten? Welche Auswirkungen hat die vermehrte Transparenz im Steuerrecht? Antworten dazu und ...

Limiting base erosion from different viewpoints

Hybrid mismatch arrangements, CFC rules, transfer pricing rules: "Limiting Base Erosion", the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most ...