Practical Problems in European and International Tax Law: Essays in Honor of Manfred Mössner

Essays in Honour of Manfred Mössner

Practical Problems in European and International Tax Law
This Festschrift in honour of Manfred Mössner delves into the practical issues in European and international tax law.

Why this book?

This Festschrift celebrates the 75th birthday of Prof. Dr Jörg Manfred Mössner.

The contributions from 35 renowned tax experts in this volume show how the practical problems in European and international tax law are of constantly growing significance in a globalizing world. The issue of tax avoidance by multinationals has become one of the main topics in international politics and taxation, as can be seen when contemplating the current efforts on base erosion and profit shifting and the international advance on a thorough exchange of information.


Sample excerpt, including table of contents


Heike Jochum, Peter Essers, Michael Lang, Norbert Winkeljohann, Bertil Wiman.


Andrea Amatucci, Dieter Birk, Klaus-Dieter Drüen, Peter Essers, Jutta Förster, Theodoros P. Fortsakis, Gerrit Frotscher, Charles H. Gustafson, Alexander Hemmelrath, Heike Jochum, Eric C.C.M. Kemmeren, Georg Kofler, Michael Lang, Moris Lehner, Hans J. Lethaus, Hanna Litwińczuk, Jürgen Lüdicke, Jacques Malherbe, Gerard Meussen, Aage Michelsen, Włodzimierz Nykiel, Carlos Palao Taboada, Rainer Prokisch, Claudio Sacchetto, Wolfram Scheffler, Wolfgang Schön, Roman Seer, María Teresa Soler Roch, Karolina Tetłak, Thomas Töben, Frans Vanistendael, Elke Wilcox, Michał Wilk, Bertil Wiman, Frederik Zimmer.

Practical Problems in European and International Tax Law
Chapter 1 Foundation of the Contemporary Ability-To-Pay Principle in Taxation in the Thought of Saint Thomas Aquinas
Chapter 2 Trade Taxation in Germany – Principles, Justification and Reform
Chapter 3 Tax Risks: A Dynamic Interplay between Financial and Tax Accounts
Chapter 4 Cross-Border Donations in Light of the Fundamental Freedoms and Tax Reality in Germany
Chapter 5 Tax Control or Tax Morality for a Successful Tax System?
Chapter 6 Capital to be Allocated to a Permanent Establishment – A German Perspective
Chapter 7 Anatomy of a Case: The US Supreme Court and the Foreign Tax Credit
Chapter 8 AOA, BEPS, E-Commerce – “Permanent Establishment” in Flux
Chapter 9 Fair Tax Law for Europe: On the Future of the Common Consolidated Corporate Tax Base (CCCTB)
Chapter 10 Legitimacy of Tax Claims of Developing Countries on Interest and Royalties of MNEs
Chapter 11 “Horizontal Discrimination” in European Tax Law
Chapter 12 The Definition of International Traffic under Article 3(1)(e) of the OECD Model Convention
Chapter 13 Application of the European Union’s Fundamental Freedoms, the Charter of Fundamental Rights of the European Union and the European Convention on Human Rights with Regard to Church Tax
Chapter 14 The Borderline between Corporate and Income Taxation for Non-Physical Persons under Modern Company Taxation: Paths to Europeanization of German SMEs
Chapter 15 Controversies around the Introduction of a General Anti-Avoidance Rule in Poland
Chapter 16 Subject-to-Tax Clauses in Tax Treaties – A German Experience
Chapter 17 Cost Contribution Arrangements and Cost Sharing Agreements
Chapter 18 Abuse of Tax Law in the European Union:Some Recent International and European Developments
Chapter 19 Action against International Tax Evasion and Avoidance by the Use of Tax Havens
Chapter 20 Functional Heterogeneity of Tax Law Language, the Problem of Multilingualism of Tax Treaties and the Protection of Taxpayers’ Rights
Chapter 21 The Common Law Trust under Spanish Tax Law, with a Special Reference to the Club-Trustee Time-Sharing System
Chapter 22 Treatment of Internal Cross-Border Interest Payments in the Case of Partnerships
Chapter 23 The Fiscal-Virtual Environment and Telematic Tax Law: A New Perspective (and Frontier) for Digital Economy Taxation
Chapter 24 CCCTB: Influence on Extent and Complexity of Tax Planning
Chapter 25 Destination-Based Income Taxation and WTO Law: A Note
Chapter 26 Exchange of Information between Tax Authorities: Structures and Recent Developments
Chapter 27 Exit Tax: A Fair Balance?
Chapter 28 Place of Management – An Analysis of German Case Law
Chapter 29 Can EU Tax Law Accommodate a Uniform Anti-Avoidance Concept?
Chapter 30 The Impact of the European Union on (Swedish) Tax Law, Tax Research and Tax Teaching
Chapter 31 Retroactive Tax Legislation in Norway – The Shipowner Case of 2010