International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law.
Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law.
With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
Florian Haase/Georg Kofler
: Preface
Section I: History and Scope of International Tax Law
1: Marilyne Sadowsky: The History of International Tax Law
2: Roberto Bernales Soriano: From the "1920s Compromise" to the "2020s Compromise"?
3: Rainer Prokisch: Sources of Law and Legal Methods in International Tax Law
4: Fadi Shaheen/David Rosenbloom: Jurisdictional Underpinnings of International Taxation
5 International Tax Law and Customary International Law: Elizabeth Gil García:
6: Craig Elliffe: International Tax Law and its Influence on National Tax Systems
7: Michael Dirkis: International Tax Law and Personal Nexus
8: Akhilesh Ranjan: International Tax Law and Low- and Middle-Income Countries
9: Reuven S. Avi-Yonah
: International Tax Law: Status quo, Trends and Perspectives
Section II: Relationship between International Tax Law and other Legal and Social Spheres
10 International Taw Law and Private International Law: Polina Kouraleva-Cazals:
11: Christiana HJI Panayi/Katerina Perrou: International Taw Law and Public International Law
12: M. André Vinhas Catão/V. Souza: International Tax Law and Corporate Law
13: Servatius Van Thiel: International Tax Law and International Trade Law
14: Werner Haslehner: International Tax Law and Economic Analysis of Law
15: Florian Haase: International Tax Law and Language
16: Marco Barassi
: Comparative Tax Law
Section III: Selected Issues on Tax Treaties and International Tax Law
17: Gianluigi Bizioli: Qualification Conflicts and Tax Treaties
18: Paolo Arginelli: Triangular Cases and Tax Treaties
19 The Future of Avoiding Double Taxation: Martin Berglund:
20: Sigrid Hemels: Charities in Tax Conventions
21: Xavier Oberson: Exchange of Information in Tax Treaties
22: Nadia Altenburg/Dietmar Gosch: Beneficial Ownership and Tax Treaties
23 The Principal Purposes Test under Tax Treaty Law: Robert J. Danon:
24: Philip Baker, KC: Tax treaties and Human Rights Law
25 Taxation of International Partnerships: Ton Stevens:
26: Craig West: Regional Double Tax Treaty Models
27: Miranda Stewart: Unilateralism, Bilateralism and Multilateralism in International Tax Law
28: Sunita Jogarajan
: Agents in International Tax Treaties
Section IV: Legal Aspects of International Transfer Pricing
29: Miguel Teixeira de Abreu: The Role of Article 9 OECD MC
30: Yuri Matsubara/Clemence Garcia: OECD Transfer Pricing Guidelines and International Tax Law
31: Matthias Hofacker: Corresponding Adjustments
32: Georgios Matsos
: Transfer Pricing versus Formulary Apportionment
Section V: The Europeanization of International Taw Law
33: Adrian Cloer: The Role of the ECJ in the Development of International Tax Law
34: Marjaana Helminen: Tax Treaties and EU Fundamental Freedoms
35: Patricia Lampreave Márquez: State Aid and International Taxation
36: Patrick Knörzer: International Tax Law and the EEA/EFTA
37: Savina Mihaylova-Goleminova: 21st Century Tax Challenges of EU Candidate Countries
38: Paloma Schwarz: European Anti-Tax-Avoidance Regimes
39: Isabelle Richelle
: Alternative Dispute Resolution in the European Union
Section VI: Selected Issues of Cross-Border Indirect Taxation
40: Roberto Scalia: Cross-Border VAT Aspects: The EU Approach and Evolving Trends
41: Thomas Bieber: Taxation of Imports
42: Heidi Friedrich-Vache: "White supplies" and Double Taxation in Cross-border VAT Law
43: Eleonor Kristoffersson
: A Comparison between EU VAT Law and the OECD VAT/GST Guidelines
Section VII: Recent International Tax Trends in Major Economies and Regions
44: Kimberly Clausing: The US Perspective on International Tax Law
45: Bristar Mingxing Cao: The Chinese Perspective on International Tax Law
46: Kuntal Dave: The Indian Perspective on International Tax Law
47: Fernando Souza de Man: The Brazilian Perspective on International Tax Law
48: Gerhard Kraft: The German Perspective on International Tax Law
49: Afton Titus: The Perspective of the EAC on International Tax Law
50: Masao Yoshimura
: The Japanese Perspective on International Tax Law
Section VIII: Emerging Issues and the Future of International Tax Law
51: Allison Christians: The Emerging Consensus on Value Creation: Theory and Practice
52: Aitor Navarro Ibarrola: The Allocation of Taxing Rights under Pillar 1 of the OECD Proposal
53: Joachim Englisch: Minimum Taxation under Pillar 2 of the OECD Proposal ("GloBE)
54: Natalia Quiñones: Challenges of the Emerging International Tax Consensus for Low and Middle Income Countries
55: Irma Mosquera Valderrama: Global Tax Governance
56: Georg Kofler: The Future of Labor Taxation
57: Michael Tumpel: Digitalization and the Future of VAT in the European Union
Height:258
Width:183
Spine:62
Weight:1970.00