The session on the first day was chaired by Prof. Kees van Raad.

Stefan Bachman (University of Zurich) gave a presentation on the topic "The Permanent Establishment in National and International Swiss Income Tax Law". He explained that his thesis examines the concept of permanent establishment (PE) primarily as defined in the OECD Model Convention and then goes on to discuss the concept as it is known under Swiss law. The thesis will also consider how well the PE concept is able to deal with current and future challenges, particularly in light of globalization and technological advancements. He pointed out that the concept in Swiss law is similar but not identical to that found in the OECD Model and that his thesis will consider the consequences of the differences between the two. In particular, since tax treaties may limit taxation rights but do not establish taxation rights for the contracting states, the distinctions between the national and international definition of the term can lead to double non-taxation.

The discussion following the presentation revolved around the issue of whether other principles contained in the OECD Model (e.g. taxation by the state of residence in the absence of a permanent establishment in the source state) are not sufficient to deal with some of the challenges identified, as well as the potential for double non-taxation. It was also suggested that the topic may have to be narrowed further in view of the fact that the permanent establishment concept has been the subject of extensive research in the past.

The presentation by Teemu Sakari Lindfors (University of Helsinki) was on the topic "The Taxation of Permanent Establishments in International Banking." His thesis identifies the peculiar problems associated with the taxation of branches of international banks within the current international tax system. He stated that these involve, in particular, the attribution of income to a foreign branch in cases involving interest spread income from traditional banking business, investment income from global trading activities conducted by a branch making use of the bank's own assets, and commission income from various activities. He pointed out that the choice of a suitable arm's length method in such cases would be problematic in view of the peculiar role and functions played by a branch in each of these cases. His thesis is therefore aimed at determining the possible solutions to such problems.

The discussion which followed was focused on whether the capital requirements for banks under various countries' laws represent an attempt to establish an arm's length standard, or whether such laws merely set a minimum threshold for compliance. The need to pay attention to issues raised by developments in exchange rates in the country of residence and the country in which the permanent establishment is located was also considered.

The interpretation of tax treaties was the subject matter of the presentation by Ms Ann-Sophie Nilsson (Jönköping International Business School, Sweden). She identified the need for tax treaty interpretation and the means for resolving differences in interpretation that may arise as a result of the application of the internal laws of the contracting states, the provisions of the Vienna Convention on the Law of Treaties and European Community law. The focus of her thesis is primarily on Swedish practice in this area, but the experience of other countries in the Nordic region, the European Union and the United Kingdom will be drawn upon. Other issues to be covered include the status of the commentaries to the OECD Model, the possible classification of such commentaries, the relevance of foreign case law in treaty interpretation by a state, and different perspectives by taxpayers and states on treaty interpretation.

The discussion that followed focused on the status of the commentaries to the OECD Model Convention, in particular whether they have legal effect under domestic law, and whether they can be considered to represent the ordinary meaning of a treaty in terms of the provisions of the Vienna Convention on the Law of Treaties. This was followed by a discussion of the feasibility of states simply including a reference to the commentaries as the authoritative source for the interpretation of tax treaties. It was also pointed out that in view of the amount of research that has already be done on the topic, it is necessary to narrow the topic to focus on specific issues that would add to the existing knowledge in the area.

Ms Daria Kononenko's (University College, London) presentation was on the topic "International Taxation of Dividends and Interest: Comparative Study of Russia and the UK". She emphasized the legal measures Russia has taken in its desire to create a body of law conforming to established international tax rules, which are conducive for promoting cross-border investments, while ensuring that Russia received a fair portion of the tax from such investments. She observed that in view of the United Kingdom's developed tax system, it is helpful to compare the tax treatment of cross-border investment income (primarily dividends and interest paid by a resident company to a non-resident company) in Russia to that of the United Kingdom in order to determine in which aspects the Russian approach may be lacking. Her thesis is therefore designed to demonstrate the extent to which both countries apply uniform principles in the tax treatment of cross-border investments, whether the approach in both countries deviate from international tax rules in this area, the distinct aspects of Russia's laws, the incidence of double taxation of investment flows between both countries and relief methods applied.

Among the conclusions/observations made by the presenter were (1) the application of a classical system for the taxation of corporate distributions in Russia, compared to the integrated approach used in the United Kingdom (b) the greater attention paid by Russia to the taxation of outward income flows compared to a stronger focus on inward income in the United Kingdom and (c) the greater flexibility of rules in the United Kingdom for dealing with tax avoidance, compared to a formalistic approach in Russia.

The discussion which followed centred on the extent to which Russia may learn from the experience of the United Kingdom and other European countries regarding the taxation of investment income. Different opinions were expressed on whether the European Union presents a good example regarding the use of the tax system to enhance the freedom of movement of capital. Regarding the taxation of corporate distributions, it was noted by the presenter that it might be difficult for Russia to change its classical system to an integrated one in view of the potential loss of income such a change will occasion.

The final presentation during the first session was by Ms Le Ti Nguyet Chau (University of Groningen) on the topic "Transplantation of corporate income tax in ASEAN in the light of legal principles in different legal structures". She observed that many of the approaches to tax reform in a number of developing countries (particularly in the ASEAN region), implemented with the advice of institutions such as the IMF and the World Bank, have involved the transplanting of tax models from developed countries into developing countries. The difficulties experienced by various countries in the ASEAN region has shown that while the appropriateness of such an approach has been evaluated mainly on the basis of the economic results (e.g. revenue-raising potential), not enough attention has been paid to the legal perspective, particularly how such laws satisfy principles of certainty, simplicity, equality and fairness. Her thesis therefore seeks to address the extent to which policymakers have paid attention to such principles in tax reform, the similarities in interpretation of such principles in developed and developing countries, and whether developing countries should adopt developing country tax models instead of following the examples of similar neighbouring countries. The experience of Vietnam, Malaysia and the Philippines provide the geographical focus for the study.

The ensuing discussion focused on the practical problems associated with tax reform in developing countries. Issues discussed included the motivations for the request for technical assistance from international financial institutions by developing countries and the endemic barriers to successful tax reform (e.g. corruption). The distinction was also drawn between the desirability of particular reform packages and the conclusion of tax treaties: since developing countries invariably need to conclude tax treaties, many of such countries have chosen to hire foreign lawyers to negotiate treaties on their behalf in view of the lack of the necessary skills at the domestic level.

The second session was chaired by Prof. María Teresa Soler Roch.

Ms Anna Bärebring (Jonkoping International Business School) discussed her research on "Group Cross-Border Loss Relief within the European Community." Ms Bärebring is at the initial stage of her research. The starting point is the situation where EU Member States allow group loss relief at the domestic level, but do not provide a similar relief in a cross-border situation. The question to be analysed is whether such a distinction is compatible with the principles of neutrality and freedom of establishment (the latter being set out in Art. 43 of the EC Treaty).

For this purpose, the student will examine the methods whereby Member States implement the principle of neutrality domestically. These methods are the tax consolidation rules and the rules on the transfer of losses. Through such methods, taxation of a business carried on by either a domestic group of companies or a single company would be equal.

Furthermore, the thesis will examine whether, in a cross-border situation, Member States might be reluctant to grant such a relief, since that would entail a loss of revenue. And if this is in line with the principle of fiscal cohesion, it might nevertheless violate the principle of freedom of establishment. The thesis will therefore investigate the reasons behind Member States' denial of cross-border loss relief, and how they may be compatible with the principles of neutrality and freedom of establishment. The analysis will focus on the notions of "group" and "losses", as well as the European Court of Justice (ECJ) case law.

The audience made the following observations: the principle of neutrality is applicable more in a cross-border context as compared to a domestic situation, where the principle of equality and tax policy decisions are more relevant; only a few tax jurisdictions include provisions for tax consolidation (and tax consolidation very often represents only an option to the taxpayer. ECJ case law should be looked at in combination with the Member State's and the taxpayer's positions. Principles of capital income neutrality and capital export neutrality should also be taken into account, especially in respect of dividends and capital gains. The European Commission discussion on home state versus consolidated taxation as well as the effects of the newly introduced Societas Europea should be considered.

The impact of CFC rules and the fact that they tax positive income but do not give relief for negative income should be borne in mind. Rules on tax treatment of groups may be compared to those concerning taxation of companies and their foreign permanent establishments. In light of the Marks and Spencer case referred to the ECJ, it would be meaningful to investigate whether there is a justification for keeping the distinction between domestic vs. international group loss-relief. Administrative requirements and procedures may be introduced at a European level and influence the granting of loss relief.

In the second presentation entitled "Taxpayer's protection in judicial tax procedures: A study from a domestic and European perspective", Christian Attardi (University of Pisa) said that his objective is to analyse the impact of European Law on Italian tax legal procedure. The research will focus on the impact of European Law upon two main areas: the exercise of judicial powers and the taxpayer's judicial protection.

The first area of study, i.e. the exercise of judicial powers, will describe how the relevant legal norms are identified, interpreted and applied in the Italian tax legal procedure, in light of the new sources of law represented by the European legal order. The student will specifically consider: the question of the primacy of European Law; the procedural issues to submit a preliminary ruling request to the ECJ; and the ways Italian Tax Courts may apply European Law. The case law of both the ECJ and the Italian Constitutional Court will be examined, too.

In the second area of study, i.e. the taxpayer's judicial protection, Mr Attardi will survey a number of procedural issues. First, the Italian tax law provisions laying down the conditions for tax refund as well as the reversal of the burden of proof and the (prohibition of) witness proof will be analyzed in their compatibility with European Law (and especially with the principles of effectiveness and equality concerning the taxpayer's rights). Second, the taxpayer's position will be looked into in the context of State aids, namely: (i) in the procedures for recovering illegally granted aids; (ii) in the event the taxpayer is not eligible for tax advantages as compared to eligible taxpayers; and (iii) in the refund proceedings. Third, the protection given to the taxpayer under the arbitration-like procedure provided for by the 1990 EU Convention on transfer pricing and the protection offered under the Italian tax legal procedure will be compared. Finally, Mr Attardi intends to investigate which means of defense are available to a taxpayer who has been affected by the exchange of tax information between European Member States based on Directive 77/799/EEC.

The audience made the following observations: the taxpayer's possibility to access the ECJ through the courts of different European Member States could be investigated in a comparative way. The position of the taxpayer when States are involved in State aid cases pending before the ECJ may deserve an analysis. The effects that Arts. 26 and 27 of the 2003 OECD Model Convention, as well as the Savings Directive and the Interest and Royalties Directive (adopted on 3 June 2003) will have on the exchange of information should be taken into account.

Ms Tina Ehrke (Karl-Franz Universität Graz) gave a presentation on"The impact of EC Law on Austrian tax procedure". The starting point of the research is that tax procedures of Member States are not harmonized within the European Union. After defining the concept of "tax procedure", Ms Ehrke will consider that, on the one hand, Member States have the freedom to establish their own procedures while interpreting and implementing EC law, and, on the other hand, their power is limited by a number of EC legal principles. Among such principles, Ms Ehrke will closely examine: (i) the obligation of solidarity (as per Art. 10 of the EC Treaty) and the related principles of equality (in respect of EC law and domestic procedural rights) and effectiveness (regarding fundamental rights that courts have the duty to protect); (ii) the fundamental freedoms set out in the EC Treaty; and (iii) the general principle of protection of legitimate expectations. Such principles will be analysed in light of the case law of the ECJ.

With particular regard to Austrian tax procedure, the student will investigate the effects of the EC Law on the following two situations: (1) recovery of taxes paid in breach of EC law and the opposite view arguing that, since the taxpayer has suffered a loss in sales (or profits) because of shifting the tax down on the consumers, the reimbursement should still be allowed; (2) collection of taxes not levied in breach of EC law. Here the focus would be on the general EC legal principle of protection of legitimate expectations, operating when EC laws are interpreted and implemented at the national level. Based on this principle, the collection of such taxes could be denied even though an ECJ judgment of infringement has been subsequently handed down.

Showing the effects of the implementation of EC law by Austrian tax procedural rules, the thesis aims to prove the great importance of such rules in the creation of a Common Market.
The audience noted that, because of lack of harmonization, it would be sensible to investigate in depth and try to give a background of common principles to the concept of "tax procedures", since that expression as such may not be the most appropriate to describe the relationship between the taxpayer and the tax administration. It would be also advisable to try to formulate a definition of "legitimate expectations", and define its boundaries/scope.

João de Olivera Geraldes (University of Lisbon) presented his research on "Is the substance over form principle unilateral or bilateral?". The student's analysis starts from the consideration that a number of different legal systems have developed general anti-avoidance rules in order to counter the harmful effect that tax avoidance has on the public interest. In particular, the focus will be on the Portuguese anti-avoidance rule of 1999, in which the discrepancy between form and substance in tax matters is resolved by giving priority to the economic content of facts. In other words, in the event of abuse of form - e.g. in a sham transaction - the applicable tax provisions will still be those relating to the infringed tax provision.

He will hence investigate the nature of the concepts of "form" and "substance", and wonder whether in tax law they have peculiar meanings. He will also consider how much importance is given by the Portuguese general anti-avoidance rule to the subjective intent to avoid taxes. In his work, the student will question how the general principles of "nullum tributum sine lege" and "ability to pay" may be interpreted when dealing with anti-avoidance rules.

The aim of the thesis will be to define the scope of the Portuguese general anti-avoidance rule by inspecting the legal justification for equal taxation of different forms of the same economic substance, in light of "the right to freedom of contract". Specifically, the final objective of the student would be to hold that the taxpayer might also claim the application of the substance over form principle when that entails a less burdensome taxation. In this way, the tax administration as well as the taxpayer could use the principle equally. In this respect the student referred to the "bilateral" application of the substance over form principle.

The legal methodology adopted for the analysis would be base upon the non-classical tax law interpretation doctrines, the logics of fuzzy concepts and Kaufmann's typological approach. Portuguese, European and US case law would also be examined.

During the discussions, it was observed that the topic is very original though it may be challenging to reach a definitive conclusion. The taxpayer and the tax administration positions should be defined more clearly. It would be useful to make a comparative study of the different countries' approach to the substance over form principle. The IASC principle of "true and fair view" could also be considered. In some cases, anti-avoidance provisions may very specifically describe the mechanism implementing the principle of substance over form. In these circumstances, it may be doubtful that the taxpayer can utilize the substance over form principle in his favor.

The term "bilateral", as used in the presentation, could be understood as relating to cross-border situations, such as bilateral adjustments in application of anti-avoidance rules (e.g. thin capitalization rules). It could also be of interest to investigate how the principle of substance over form is dealt with in other branches of law.

The final presentation of Session Two, "The principle of proportionality in the American and European Tax Jurisprudence" was given by João Dacio Rolim (London School of Economics). The thesis will look into the origin and importance of the principle of proportionality in taxation. The analysis will start from the development of such principle in the United States and, subsequently, European jurisprudence. Furthermore, the student will consider how the US Supreme Court and the ECJ have interpreted such principle. The objective of the research is to investigate, through a comparative analysis, how the principle of proportionality is applied in taxation by considering the public policy, the tax administration's interests and the taxpayer's rights and fundamental freedoms.

The study will compare and draw a distinction between the US Supreme Court notion of reasonableness and the principle of proportionality. The research will subsequently focus on the importance of those two concepts in interpreting and applying - when not derogating - legal rules, especially in tax matters. Particularly, this part of the research will consider how a number of tax principles can be inferred from the proportionality principle, e.g. the legitimate expectation of non-retroactive legislation in the American and European experience.

Finally, the thesis will define the boundaries of the principle of proportionality. This would avoid abuse of the principle that potentially could lead to arbitrariness and uncertainty. The principle of proportionality would therefore be analysed in its relationship to other legal principles, such as certainty and predictability. In this way, the ultimate result would be to find a balance between the principle of proportionality and the other general principles of tax law.

The audience made the following observations: the topic of the research is very interesting, since very few works have studied the relationship between the principle of proportionality and the other legal principles. The thesis may show how the principle of proportionality, not being autonomous, is hence intertwined with all the other principles of tax law. It may be useful to stress how important the principle of proportionality is in respect of cross-border taxation.

The sessions of day 3 were chaired by Prof. Huub Bierlaagh, Joanna Wheeler and Prof. Wim Wijnen.

Dmitri Jelezniakov (University of Essex) gave a presentation on "International taxation of structuring (restructuring) of multinational business organizations: UK, US and Canada". He discussed the outline of his research including taxable, non-taxable and partly taxable transactions, legal form v. substance of the transactions, broad aspects concerning tax implications of acquisitions by way of purchase of shares and purchase of assets. As the research is in the initial stage, the issues were not discussed in detail. Joanna Wheeler and Huub Bierlaagh made some suggestions to the student regarding framework of the research.

Amar Mehta (University of Amsterdam) started his presentation with a brief discussion on the role of taxation in evolution of the contemporary leasing industry, including some of the leasing "products" tailored to meet with the requirements of favourable tax laws in some jurisdictions, for instance, "Qualified Technological Equipment (QTE) leasing" under the US Revenue Code.

Next, Mr Mehta pointed out that his thesis would give due emphasis on the aggregate effect (or the global effect) of a leasing transaction in the source state, the residence state as well as any other intermediate jurisdiction. Research would also include analysis of the relevant tax treaty aspects. He concluded his presentation by highlighting the following core research issues:

• use of special purpose vehicles and other international tax planning practices for cross-border leasing;
• double-dip leasing;
• whether and how the tax treaties and the EC Treaty limit the scope of restrictive/ anti-avoidance provisions under the domestic tax laws; and
• response by the tax authorities in the select jurisdictions to the relevant tax planning practices, and validity of such response in the context of tax treaties/EC Treaty.

Ms Irma Johanna Mosquera Valderrama (University of Groningen) opened her presentation on "Cross-border leasing: international tax aspects" by pointing out how the process of incorporation of aspects relevant for leasing in a country's legal system is influenced by legal culture explained in terms of statutory law, beliefs, attitudes and legal practice. Next, she pointed out that, for the purposes of her research, she would study legal culture in France, the Netherlands and Colombia regarding (i) identification and evaluation of the relevant principles of law, (ii) the instruments chosen to incorporate leasing in the legal system, and (iii) the interaction of private law, accountancy and tax regulations. She pointed out relevant developments in the field of tax treaties, including the OECD 1983 leasing report. She concluded her presentation with the following three questions/ propositions: (1) will the differences in the tax treatment of leasing be better explained once the study of the incorporation process of leasing in each selected country is conducted taking into account the social, legal, economic and political circumstances in each selected country's legal system (2)in the light of the different legal cultures affecting international tax regulations is the draft of the new international tax rules regarding cross-border leasing feasible in order to contribute to the good development of the principles of tax law such as neutrality, efficiency and transparency reducing the current differences in leasing in each legal system (3) will the concept of legal culture provide elements for a more comprehensive approach to the recent trends in international law mainly with regard to tax and accountancy regulations?

Ms Annika Riedel (Max Planck Institute for Intellectual Property, Competition and Tax Law) gave the next presentation. Her subject was "Transfer pricing regulations of the USA, Sec. 482 IRC, in comparison with the German administrative principles and the OECD Guidelines for multilateral enterprises with emphasis on intangibles and services - necessity and ideas of harmonization in the EU and worldwide".

Ms Riedel commenced her presentation by stating that her Ph.D. work arose from the subject of transfer pricing documentation and penalties and, as a part of her research, she would investigate the US and German regulations as well as the OECD Guidelines. She mentioned that determining arm's length pricing of intangibles is difficult for taxpayers as well as tax administration, and sufficient documentation may help to identify intangibles and determine arm's length prices. She discussed relevant aspects of OECD Guidelines concerning documentation and penalties, relevant parts of the German regulations (previous law) as well as the new German transfer pricing documentation requirements and penalty aspects. She opined that the new German penalty provisions are incompatible with EC principles, and proposed that harmonization of documentation requirements by various jurisdictions could be a more effective approach. She emphasized that tightened documentation requirements and appropriate penalty provisions are necessary for Germany to prevent loss of revenue to other jurisdictions such as the United States.

She concluded her presentation with the following three questions/propositions: (1) who should bear the burden of proof; (2) tax competition vis-à-vis documentation requirements and penalties; and (3) the need to harmonize documentation requirements.

Torre Delgadillo Vicente (Complutense University of Madrid) gave the final presentation of Session Three. His thesis is on intangible transfer pricing taxation.

Mr Torre started his presentation by highlighting how globalization, epitomized by the advent of electronic commerce, has changed the pattern of trade transactions, and enabled companies to make increased use of intangible property and quickly transfer capital from one place to another. He then discussed the problems, viz. (i) the trend of cross-border exchange of intangibles between related companies, (ii) lack of international regulations in respect of such exchanges, and (iii) little or no unrelated party transaction information (benchmarks). He also highlighted that multinational enterprises have been developing artificial tools for avoiding taxes, such as transfer pricing manipulations, use of base companies and conduit companies in tax havens, and treaty shopping.

He concluded his presentation by raising the following research questions: (1) will soft law reduce sovereignty of countries (2) what is the function of a soft-law instrument (3) what are the States and international organizations doing to perfect the soft-law instruments?

Prof. Hugh Ault chaired the session.

The first presenatation was given by Ms Elizabeth Frixione (University of Genoa) on Port and Maritime "Taxes". She presented the legislative background in Italy and its evolution, in particular with reference to the creation of "port authorities". One of the main issues she will deal with in her dissertation is the characterization of this type of levy. She questioned whether payments for port operations could be considered as taxes, as special contributions or as custom duties. From her point of view, this should be determined on the basis of the recipient of the levy.

Moreover, she highlighted the difficulties arising from the fact that depending on the circumstances, the proceeds of port and maritime "taxes" are attributed totally or partly to the State, putting ports in a difficult financial situation. Her final goal is to find a solution to these issues.

Prof. Ault had a strong interest on the subject and suggested considering how these problems are dealt with in cases concerning airport taxes and toll roads.

Ms Mona Aldestam (University of Uppsala) gave a presentation on the application of EC State aid rules to taxation.

She described the main features of the rules regulating State aids in the EC Treaty and concluded that they could be applied also to taxes. She pointed out, however, the problems related to the identification of the selectivity criterion as a condition to consider a domestic measure as State aid. She found out that the issue has been solved through the "derogation method", according to which only derogations from a generally applicable tax system favoring certain undertakings or the production of certain goods can constitute State aid. In this respect, the focus moved on the identification of the "norm" (benchmark tax system).

Prof. Ault agreed with her point of view and suggested looking at a publication by Prof. Fichera on the concept of income and tax systems. Further, he mentioned some cases at the WTO (World Trade Organization) level, in which the United states was involved, to highlight the difficulty of defining the benchmark tax system.

Giovanni Mameli (University of Bologna) continued the discussion started by Ms Aldestam and referred to the relationship between State aid rules and the Code of Conduct in the framework of domestic tax measures. After a general description of the two sets of rules, he demonstrated the existence of a strict link between them. He argued that the Code of Conduct attributes to the Commission broad authority in the field of direct taxes. His point of view is that, even though a soft-law tool, the Code of Conduct may be extremely relevant in achieving harmonization in the field of direct taxes.

Prof. Ault replied that he agrees and he suggested that Giovanni focus more on the technical issues than on the political ones, in order to provide the way to find a solution that then will obviously need to be accepted at a political level.

The fourth presentation of Session Four was given by Ms Annette Bruzelius (University of Lund). She also joined the discussion started by Ms Aldestam and continued by Giovanni and pointed to the definition of "tax competition" in general terms. She pointed in particular to two aspects of tax competition: the intention and the specificity. She highlighted a number of problems with reference to the difficulty of demonstrating the existence of the different elements that constitute tax competition.

Prof. Ault pointed out that the bottom line should be whether the country internally bears the consequences of the measure. Further, he referred to the approach undertaken at the EU level of having a harmonized tax basis. This will, in his view, push countries to the lower their tax rates in order to compete with other EU countries. Ms Wheeler asked how the intention of a state could be found.

Ms Bruzelius pointed to parliamentary works, preambles and accompanying documents as tools to ascertain a state's intention when passing a law.

Ms Natalia Beruashvili (University of Edinburgh) gave the last presentation of the session. She dealt with the harmonization of interest income taxation in the European Union and with the problems it is supposed to solve, i.e., tax evasion, tax avoidance and harmful tax competition. She declared herself surprised of the approval of the tax package at the EU level and pointed to the main implementation problems of the Savings Directive. In particular, she referred to definition of interest income, to the concept of beneficial owner, to the definition of paying agent under the directive and to the administrative burden for paying agents.

Prof. Ault highlighted the differences between the approved text and its prior proposal but at the same time expressed skepticism on the effects of its application. His skepticism is mainly due to the fact that there is no final date at which the Directive will be applicable and that it is unlikely that taxpayers who hold money in banks outside the European Union will declare their income.

Ms Jeanette Yackle, Head of Reference for International, Foreign and Comparative law, Harvard University law Library, gave two afternoon seminars on the practical use of research tools. Ms Viola Habakuk of IBFD offered the opportunity of exploring the legal research possibilities of the Internet. Prof. Frans Sonneveldt of the University of Utrecht and Prof. John Tiley of the University of Cambridge gave an afternoon seminar in which they looked at case studies illustrating the civil law and common law approaches to tax avoidance. In the week following the meeting, English-language tutoring, with an emphasis on international tax terminology, was offered as an option.