Author Description

On 23-24 May 2014, the 'Tax Treaty Case Law around the Globe' conference was held at Tilburg University. The conference was jointly organized by the European Tax College of Tilburg University and the Institute for Austrian and International Tax Law of WU. The conference was dedicated to an analysis of the most important cases on international tax treaty law decided in 2013 in different tax jurisdictions worldwide. 39 cases were presented by leading tax experts from 24 countries. Each report in this book is dedicated to a court case or a number of cases on a particular article of the tax treaty at issue (often based on the OECD or UN Models) that was decided in a certain jurisdiction in 2013. The reports are structured and presented in a similar way, i.e. (i) the facts of the case, (ii) the decision and reasoning of the court and (iii) the observations of the authors, including the possible impact of the decision on international tax law development in the respective country and other jurisdictions. This clear and concise structure enables a solid and accessible overview of the 2013 case law on tax treaty application. The book consists of seven parts: part 1: tax treaty interpretation and PE; part 2: business profits and personal independent services; part 3: dividends, beneficial ownership and capital gains; part 4: royalties; part 5: labour income; part 6: other income, avoidance of double taxation and non-discrimination and part 7: exchange of information, legal protection and retroactivity.