Tax Rules in Non-Tax Agreements

Tax Rules in Non-Tax Agreements
Written by experts from around the globe, the book examines the relevance of tax rules in non-tax agreements and highlights problematic issues in this important field of tax law.

Why this book?

Tax rules in non-tax agreements is a topic of great relevance in practice. Yet, up to now, this area of tax law has been generally neglected by researchers. The aim of this book is to close this gap in tax law research and to analyse the provisions of international agreements and similar legal instruments under international law which provide for a special domestic law tax treatment for specific individuals and international organizations.

Twenty-three national reports from countries across the globe have been compiled and are published in this volume. Seventy experts, including the authors of the national report, convened for a joint conference on “Tax Rules in Non-Tax Agreements” in Rust (Austria) from 7-9 July 2011. The national reports focus on the interaction of tax rules in non-tax agreements with the corresponding tax treaty rules. Moreover, possible matters of dispute regarding the justification of these tax rules within the legal and political frameworks of the different states are given much attention. The objective of this book is to show the relevance of tax rules in non-tax agreements, to highlight problematic issues and to encourage future research in this important field of tax law.


Sample excerpt, including table of contents


Michael Lang is Head of the Institute for Austrian and International Tax Law. He is also Academic Director of the LLM Program in International Tax Law and Speaker of the Doctoral Program in International Business Taxation at Vienna University of Economics and Business (WU), Austria.

Pasquale Pistone holds the Ad Personam Jean Monnet Chair in European Tax Law and Policy at WU. He also is Associate Professor of Tax Law at the University of Salerno, Italy.

Josef Schuch is a professor of tax law at WU and a partner of Deloitte Austria.

Claus Staringer is a professor of tax law at WU and a principal consultant with the law firm Freshfields Bruckhaus Deringer.

Alfred Storck is a visiting professor at the Institute for Austrian and International Tax Law, WU.


Kristiina Äimä, Christine D. Allie, Almudí Cid, Kathrin Bain, Tomas Balco, Mateus Calicchio Barbosa, Yariv Brauner, Catherine Brown, Hyejung Byun, Brian Cleave, Katharina Daxkobler, Stefano Dorigo, Thomas Dubut, Daniela Endres, Emrah Ferhatoğlu, Joakim Frände, Cristián Andrés Gárate González, Corinne Grigoriu, Peter Hongler, Roland Ismer, Keisaku Koga, Svetislav V. Kostić, Richard Krever, Krzysztof Lasiński-Sulecki, Alastair McKinnon, Danuše Nerudová, Isabelle Richelle, Luís Eduardo Schoueri, Daniël S. Smit, Edoardo Traversa, Vladimir Tyutyuryukov, Félix Alberto Vega Borrego, Barbara Vintras, Minna Wallin, Yan Xu.

Tax Rules in Non-Tax Agreements
Chapter 1 General Report
Chapter 2 Australia
Chapter 3 Austria
Chapter 4 Belgium
Chapter 5 Brazil
Chapter 6 Canada
Chapter 7 Chile
Chapter 8 Czech Republic
Chapter 9 Finland
Chapter 10 France
Chapter 11 Germany
Chapter 12 Hong Kong
Chapter 13 Italy
Chapter 14 Japan
Chapter 15 Kazakhstan
Chapter 16 The Netherlands
Chapter 17 Poland
Chapter 18 Russia
Chapter 19 Serbia
Chapter 20 South Korea
Chapter 21 Spain
Chapter 22 Switzerland
Chapter 23 Turkey
Chapter 24 United Kingdom
Chapter 25 United States
Appendix 1: QuestionnaireTax Rules in Non-Tax Agreements
Appendix 2: List of Authors

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