Tax Treaty Case Law around the Globe 2023 (eBook)

Series on International Tax Law, Volume 140

Georg Kofler, Michael Lang, Alexander Rust, Jeffrey Owens, Pasquale Pistone, Josef Schuch, Karoline Spies, Claus Staringer, Rita Szudoczky, Peter ESSERS, Eric Kemmeren, Cihat Öner, Daniel Smit (Herausgeber)

eBook Download: EPUB

2024 | 1. Auflage
360 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1341-8 (ISBN)

Infos

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 29 most important tax treaty cases that were decided around the world in 2022. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases.

With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2023 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.

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VIIList of Contributors

is a practicing barrister and King’s Counsel, practicing from chambers in Field Court, Gray’s Inn. Additionally, he is visiting professor at the law faculty of Oxford University and a senior visiting fellow at the Institute of Advanced Legal Studies, University of London. He specializes in international aspects of taxation which covers both corporate and private client matters. He has advised and represented several governments on tax matters and appeared as an expert in cases around the world. He has particular interest in taxation and the European Convention on Human Rights, is author of a book on double taxation conventions, and editor of the International Tax Law Reports. He was one of the general reporters on the Practical Protection of Taxpayers’ Rights for the International Fiscal Association Congress in Basel in 2015 and is one of the directors of the Observatory on Protection of Taxpayers’ Rights.

holds an LL.M from the Brazilian Institute for Tax Law (IBDT) and an LL.B. from the University of São Paulo. He is an associate at Lacaz Martins, Pereira Neto, Gurevich & Schoueri Law Firm.

(Prof. Dr.iur, Rechtsanwalt) is a judge at the Federal Supreme Court of Switzerland where he is – inter alia – sitting on tax cases. In addition, he has been lecturing on tax law at the University of Zurich since 2001. Being the co-editor of Commentaries on Swiss Tax Law, he has also published numerous articles in various fields of (international) tax and (general) procedural law.

is full professor at the University of Lisbon and has been visiting professor at other European, American, and African Universities and at the MoF Training Institute in Taiwan. She is editor-in-chief of Intertax and a member of editorial boards and scientific committees of several other European tax journals. She has chaired transfer pricing arbitration committees, acted as an expert at the legal department of the IMF, and has drafted and negotiated tax reforms in Portuguese-speaking countries. She was a delegate for Portugal in working groups for direct tax harmonization at the European Community and in the working group for tax evasion and avoidance at the OECD. Dourado is a founding member of the Group for Research in European and International Taxation (GREIT). She is vice president of the Institute for Fiscal, Tax and Economic Law (IDEFF). She was also a member of the European Association of Tax Law Professors (EATLP) Executive Board (2013–2017) and Academic Committee (2018–2020; 2006–2012). She has published widely on international, European, and comparative tax law.

is professor of law and director of the Tax LLM program at the Peter A. Allard School of Law at the University of British Columbia. Professor Duff has published numerous articles on tax law and policy, is the lead author of (7th ed., 2022) and (2nd ed., 2019), and the sole author of (forthcoming 2024). He is a member and former governor of the Canadian Tax Foundation, a member of the International Fiscal Association, and the governing council of the Canadian branch of the International Fiscal Association, a member of the editorial board of the Canadian Tax Journal, and an international research fellow of the Oxford University Centre for Business Taxation.

is an associate professor in the Department of Law and Governance at the Norwegian Business School BI. He has also a 20% position at the University of Stavanger where he is mainly responsible for EU/EEA law at the bachelor level and is a member of the national complaint board for tax matters. Before joining the Norwegian Business School BI, he worked as a tax lawyer at KPMG Law for four years and five years for the Norwegian tax authorities. Eivind obtained an advanced LL.M. in international tax at the International Tax Center (ITC) in Leiden and his Ph.D. from the University of Oslo. Further, he is a board member of the Nordic Tax Research Council, member of the academic committee of European Association of Tax Law Professors (EATLP), editor of the Norwegian tax journal “Skatterett”, responsible for updating IBFD’s information regarding the individual and corporate tax system in Norway, responsible for legal comments on direct and indirect tax law at Karnov Group Norway, and is a member of the editing board of the Nordic Tax Journal.

is an assistant professor in international tax law and European tax law at Tilburg University. From 2015 to 2018, he was a research associate and postdoctoral research fellow at IBFD Academic (Amsterdam, the Netherlands). He was educated at the University of Seville where he graduated in law in 2002. He holds a master’s degree in taxation from the Instituto de Estudios Fiscales/University of Seville (Spain) and an advanced master’s degree in comparative, European and international law from the European University Institute (EUI). He received his Ph.D. from the EUI in 2015 with a thesis on the preliminary ruling procedure and direct taxation that was awarded the prize for the best doctoral thesis by the Association of Professors of Tax Law. Before joining the EUI in 2010, he worked for seven years as a tax practitioner in taxation concentrating on tax due diligence and audits, real estate taxation, mergers and acquisitions, and litigation.

is a professor of international company law at the Copenhagen Business School and was a member of the committee that prepared the Danish Companies Act of 2009. His research deals with Danish company and tax law as well as European company law and tax law.

is a professor in tax law. After having defended his PhD at the Paris I Panthéon-Sorbonne University in 2017, he became assistant professor at the Paris II Panthéon-Assas University in 2018. In 2020, he was appointed full professor. Currently working for the University Lumière Lyon 2, he specializes in international tax law and international trade.

graduated as a lawyer (master of laws) from ELTE University of Budapest and holds an LL.M. degree in international business taxation obtained at Tilburg University. He was working at the WU (Vienna University of Economics and Business) as a research and teaching associate, and he obtained his PhD degree there within the framework of the DIBT program. Currently, he is working at the international tax services department of PwC Hungary. Additionally, he is a lecturer at the Financial Law Department of ELTE University.

is a Masters in Law from Golden Gate University, USA. She is also a Chartered Accountant from the Institute of Chartered Acocuntants of India and a commerce graduate from Mumbai University India. She has nearly 25 years of experience in advising Fortune 500 multinationals on corporate international tax and transfer pricing matters, Apart from this, Seema advises clients in tax policy matters. She has co-authored several publications, regularly speaks at global seminars and contributes to research papers and columns on tax and transfer pricing policy that find mention in leading academic publications such as IBFD, Kluwers, Bloomberg, Tax Notes, etc.

is professor of international taxation and international tax law at the Fiscal Institute Tilburg of Tilburg University in the Netherlands. As of 1992, he is Of Counsel with Ernst & Young Tax Advisers and, as of 2007, he is a Deputy Justice of the Arnhem Court of Appeals (Tax Division), the Netherlands. In 2001, he obtained his PhD from Tilburg University with a thesis entitled Principle of Origin in Tax Conventions, A Rethinking of Models. He is an editor of the EUCOTAX Series on European Taxation and chair of the editorial board of EC Tax Review published by Kluwer Law International. Furthermore, he is a co-initiator and coordinator of the EUCOTAX Network and the EUCOTAX Wintercourse. He was also a visiting scholar at New York University (spring 1999) and Short Term Consultant of the International Finance Corporation (Member of the World Bank Group, Washington, DC 2004). He regularly gives guest lectures at foreign universities (visiting professor, inter alia, at WU Vienna, Université de Panthéon-Sorbonne (Paris I) (Paris), Northwestern University (Chicago), and Luiss (Libera Università Internazionale degli Studie Sociali, Rome), Katholieke Universiteit Leuven (Belgium), University of Florida (Gainesville) and is a frequent speaker at international congresses, seminars, and courses. Furthermore, he has been a member of the ECJ Task Force of the Confédération Fiscale Europeénne since 2011 and was head of the Department of Tax Economics (2013–2019) and member of the Advisory Commission EU Arbitration Convention for the Netherlands (2013–2019). He was and is a member of various academic and non-academic commissions.

is a professor at the University of Western Australia Law School, Perth,...

Produkt-Details

• Erscheint lt. Verlag: 17.4.2024
• Sprache: englisch
• Themenwelt: Recht / Steuern ► Steuern / Steuerrecht
• ISBN-10: 3-7094-1341-9 / 3709413419
• ISBN-13: 978-3-7094-1341-8 / 9783709413418