The History of Double Taxation Conventions in the Pre-BEPS Era

This book analyses the evolution of tax treaties practices from the early days of the history of international taxation until the beginning of the BEPS era.

Why this book?

The design of international tax law cannot be described without recourse to its extensive history. By looking at the evolution of tax treaties, valuable insight is gained as regards the causes behind the most recent shift towards renewed international tax coordination in the framework of the BEPS Project. This book analyses how tax treaties have evolved, from the early days of the history of international taxation until the beginning of the BEPS era, by collecting the outcome of joint research on the development of international tax law. It consists of a wide range of papers bridging the existing gap between the history of international law, economic history and the history of international cooperation.

In this context, it also spells out the importance of the role of early institutions such as the International Chamber of Commerce and the League of Nations, as well as the International Fiscal Association and the OEEC/OECD, and helps to highlight their fundamental influence. The book is the result of the conference “History of Double Taxation Conventions”, which took place from 3-5 July 2008 in Rust/Neusiedler See. It consists of 30 contributions exploring the development of the tax treaty practices of 30 countries and, additionally, three cross-sectional contributions.

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This book is part of the WU Institute for Austrian and International Tax Law - Tax Law and Policy Series

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Editor(s)

Michael Lang is professor at WU Vienna University of Economics and Business, Institute for Austrian and International Tax Law. Ekkehart Reimer is professor at Heidelberg University, Institute for Public Finance and Tax Law.

Contributor(s)

Raymond Adema, Tiiu Albin, José Almeida Fernandes, Hrvoje Arbutina, John F. Avery Jones, Tomas Balco, Christoph Bräunig, Yariv Brauner, Kim Brooks, Irene Burgers, Brian Cleave, Dev R. Erriah, Friederike Gorgiev-Oberascher, María Amparo Grau Ruiz, Charles H. Gustafson, Lidija Hauptman, Judita Holczerová, Chaowu Jin, Horace King, Borbála Kolozs, Franz Koppensteiner, Nataša Žunić Kovačević, Jana Kubicová, Georgios Matsos, Yuri Matsubara, Shay N. Menuchin, Irma Johanna Mosquera Valderrama, Danuse Nerudova, Bettina zur Nieden, Helen Pahapill, Andrea Parolini, Ciprian Adrian Păun, Susanne Raas, Daniel P. Rentzsch, Isabelle Richelle, Luís Eduardo Schoueri, Nico Schutte, Andrew M.C. Smith, Viktar Strachuk, Sabina Taškar Beloglavec, C. John Taylor, Karolina Tetłak, Andreas Their, Edoardo Traversa, Richard Vann, Danil V. Vinnitskiy.