Editors
Contributors
Preface
CHAPTER 1
Tax Competition and Tax Cooperation: A Survey and Reassessment
Hugh J. Ault
CHAPTER 2
Current Issues on Treaty Interpretation
John Avery Jones
CHAPTER 3
Corporations Should Not Be Taxpayers, Especially Post-BEPS
Yariv Brauner
CHAPTER 4
The Anti-Tax Avoidance Directive under Scrutiny: A Matter of Competence?
Cécile Brokelind
CHAPTER 5
Arbitrating Cross-Border Tax Disputes in Line with European Union Law: Issues and Solutions
Ana Paula Dourado & Pasquale Pistone
CHAPTER 6
Equal Tax Treatment of Legal Forms for Businesses in International Tax Law
Peter H.J. Essers
CHAPTER 7
Treaty Allocation Rules, Corresponding Adjustments and Binding Arbitration: A Coherent Method to Prevent Double Taxation
Carlo Garbarino
CHAPTER 8
Annals of U.S. Tax Policy: Taxing Income That Isn’t
Charles H. Gustafson
CHAPTER 9
From Marks & Spencer to Bevola: A French Outlook
Daniel Gutmann
CHAPTER 10
The Impact of the TFEU Basic Freedoms on the Tax Treatment of Intra-EU Investment Income
Marjaana Helminen
CHAPTER 11
If We Need a Destination-Based Corporate Income Tax, Do We Also Need a Production-Based Consumption Tax?
Eric C.C.M. Kemmeren
CHAPTER 12
Academic Exchange under Convention Law
Steffen Lampert & Heike Jochum
CHAPTER 13
Are Football Referees Sportspersons?
Michael Lang
CHAPTER 14
Tax and Social Security Treaties in Japan: Towards the New Era of Japan’s Global Worker Policy
Yuri Matsubara
CHAPTER 15
The Dependent Agent PE Rule in the French Google Case: A Case for a Google Tax?
Jérôme Monsenego
CHAPTER 16
Return of Capital Reserves Cross Border in Europe and Beyond: Some German Peculiarities
Joerg Manfred Moessner
CHAPTER 17
Incentives? What Incentives?
H. David Rosenbloom
CHAPTER 18
What a Separate Budget for the Euro Would Look Like
Frans Vanistendael
CHAPTER 19
Four Suggestions to Improve the Consistency and Efficiency of the OECD Model’s Distributive Rules
Kees van Raad
Selection of Bertil Wiman’s publications (1986-2018)
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