International Taxation in a Changing Landscape: Liber Amicorum in Honour of Bertil Wiman

International Taxation in a Changing Landscape contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Prof. Wiman is one of the founding members and former chairman of EATLP, and former vice president of IFA. The general subject selected for this Liber Amicorum in honour of Bertil Wiman (‘The Changing Landscape of International Taxation’) is particularly timely, not only because the international tax landscape is indeed changing, but also as Bertil has touched on many of the features of that ‘changing landscape’ in his writings over the years. This book contains analyses of key topics of international taxation by offering a global perspective, assessing the practical impact of certain new international rules and their compatibility with EU law, and examining the trends and possible future developments.

What’s in this book:

The essays cover various topics in the field of international tax law, with a major focus on corporate taxation, an area to which Prof. Dr Bertil Wiman dedicates most of his research. The book includes authoritative analyses by acknowledged experts on several international tax topics, which illustrates the growing complexity of this area together with its rapid evolution.

The book contains analyses of key international topics, such as:

• the tax challenges of the digitalization of the economy;
• the resolution of international tax disputes;
• the principles for the taxation of corporations;
• EU tax law;
• transfer pricing; and
• tax treaty law.

How this will help you:

The depth of the essays contained in this book mirrors the importance of the contributions of Prof. Dr Bertil Wiman to the international tax community. It will also prove to be of great value to policymakers, tax practitioners and academics as an authoritative, comprehensive guide to important issues in the complex area of international taxation.

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)