Brochure 20112013

INTERNATIONAL TAX LAW VIENNA
http://www.international-tax-law.at
2011/13
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Contents
Welcome to Vienna Contact / Information Program overview Aims and academic qualifications Program options Admission Program location Study fee Academic degree Prerequisites Records on academic performance Credits Academic management Faculty
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Course schedule Course contents Alumni Calendar
Registration / Application form
Imprint
Copyright LL.M. Program in International Tax Law WU / Institute for Austrian and International Tax Law c/o Akademie der Wirtschaftstreuhnder Schnbrunner Strae 222-228/1/6/3 A-1120 Vienna Contents Prof. Michael Lang, Gerhard Stangl Texts Prof. Michael Lang, Barbara Ender-Rochowansky Layout and design Grafikstudio Sacher GmbH, A-1130 Vienna Last updated July 2010. Subject to change.
Welcome to Vienna
In a time of globalization, international tax law has gained in importance. The LL.M. program at the WU meets the increasing demands for training and education by offering courses the intensity of which is second to none worldwide. The main emphasis is on conveying specialist knowledge in international tax law, as well as on making an interdisciplinary link to related areas of knowledge. With renowned experts from all over the world as lecturers, education at the highest international level with a great degree of practical relevance is guaranteed.
WienTourismus/Claudio Alessandri
This program was devised at the Institute for Austrian and International Tax Law of the WU (Prof. Michael Lang, Prof. Josef Schuch, Prof. Claus Staringer, Prof. Pasquale Pistone, Prof. Alfred Storck); the Institute has specialized in lecturing on and research in international tax law for many years. Comprehensive networking with professionals in this field, renowned scholarship and widely acknowledged achievements in research, and a broad range of partnerships with researchers from Austria and abroad have created the preconditions for expanding the course offerings to postgraduate education.
WienTourismus/Gerhard Weinkirn
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WienTourismus/Peter Rigaud
WTV/Willfried Gredler-Oxenbauer
On behalf of the Akademie der Wirtschaftstreuhnder, Barbara EnderRochowansky is responsible for managing and overseeing the program. The Akademie der Wirtschaftstreuhnder has a proven and comprehensive track record in the area of training and education, and thus also represents the cutting edge for our LL.M. program. Both the full-time and part-time programs are aimed at university graduates from all parts of the world who would like to acquire additional specialist knowledge, as well as at professionals wishing to participate in such a program while they continue to work.
This brochure provides details on the program. Additionally, we would be glad to meet you and provide further information in a personal discussion that will give you a deeper insight into the quality of our program. We are very much looking forward to having you as one of our students!
Prof. Michael Lang Academic Director LL.M. program in international tax law
Prof. Josef Schuch Deputy Academic Director LL.M. program in international tax law
Gerhard Stangl Managing Director Akademie der Wirtschaftstreuhnder
WienTourismus/Robert Osmark
Contact / Information
Academic management
Prof. Michael Lang WU / Institute for Austrian and International Tax Law Althanstrae 39-45 1090 Vienna Austria Phone +43 (1) 313 36-4645 Fax +43 (1) 313 36-730 michael.lang@wu.ac.at http://www.wu.ac.at/taxlaw
Organizational management
Barbara Ender-Rochowansky Akademie der Wirtschaftstreuhnder Schnbrunner Strae 222-228/1/6/3 1120 Vienna Austria Phone +43 (1) 815 08 50-15 Fax +43 (1) 815 08 50-50 b.ender@wt-akademie.at http://www.international-tax-law.at
Practical information
Austrian Exchange Service (OeAD) Alser Strae 4/1/3/8 1090 Vienna Austria Phone +43 (1) 4277-28101 Fax +43 (1) 4277-9281 info@oead.at http://www.oead.at
Partners
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INTERNATIONAL TAX LAW AT A GLANCE

Tax and Business Review SWI Steuer und Wirtschaft International
I Up-to-date expert articles geared to practical needs I Comprehensive legal directives of the Austrian Ministry of Finance I Austrian and foreign supreme court decisions on international tax law I EU news and literature survey
d structure lete wellReview a comp Including Tax and Business of online! overview in LINDE
I All ministry directives since 1991 I All Austrian tax treaties I All SWI volumes since 1997
Combined subscription package:

Tax and Business Review 2010, vol. 20, issues 112 plus online archive from 1997 up to the latest issue (excl. VAT, excl. mailing costs)
EUR 204,
www.swi.at
Tel.: +43 1 24 630 - 0 Fax: +43 1 24 630 - 23 office@lindeverlag.at www.lindeverlag.at Scheydgasse 24 1210 Wien
Program overview
Aims and academic qualifications
The LL.M. Program in International Tax Law aims to provide postgraduate education in the area of international tax law focusing on significant national tax law regimes and related areas, in particular business administration. Graduates should be in a position to skillfully apply international tax law in professional corporate, consulting and administrative environments. The Rector of the WU will confer the degree of Master of Laws (LL.M.) on graduates of the postgraduate program in accordance with the terms of the University Act. The partnership with the Akademie der Wirtschaftstreuhnder guarantees a very efficient management of the program.
Program options
This program is offered in English only, as a full-time and part-time program, with the former lasting for one academic year. Courses are scheduled on Fridays and Saturdays from 8.30 a.m. to 5.30 p.m. The remaining time is to be spent on course preparation and revision. Full-time programs commence in September 2011 and 2012. The part-time program continues over two academic years, with courses mostly held from 8.30 a.m. to 5.30 p.m. on Fridays and Saturdays. The part-time program commences in September 2011. A wide range of courses is available for students opting for the full-time programs (2011/2012 or 2012/2013), as well as for part-time students (2011/2013).
Admission
A university degree is a precondition for admission. The head of academic management will decide whether a similar or comparable qualification results in eligibility for the program. The number of places is limited. In the case of equal qualifications the date of application will be decisive as to which applicants are selected.
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Program overview
Program location
With the exception of one course in Brussels, all courses are held in Vienna at the WU / Institute for Austrian and International Tax Law and the Akademie der Wirtschaftstreuhnder. Both institutions are well served by the public transport network. WU / Institute for Austrian and International Tax Law Althanstrae 39-45 A-1090 Vienna Prof. Michael Lang Phone +43 (1) 313 36-4645 Fax +43 (1) 313 36-730 http://www.wu.ac.at/taxlaw Akademie der Wirtschaftstreuhnder Schnbrunner Strae 222-228/1/6/3 A-1120 Vienna Barbara Ender-Rochowansky Phone +43 (1) 815 08 50-15 Fax +43 (1) 815 08 50-50 http://www.international-tax-law.at
Program fees
The program fees, as assessed by the University Panel of the WU, amount to EUR 11,900 for both the full- and parttime programs. This includes all materials made available by the lecturers as well as examination fees. Travel and accommodation expenses, and in particular costs incurred for the course held in Brussels, must be borne by the program participants.
An incredibly enriching and r ewarding educational experience. Shauna Pittman, Canada, Full-time 08/09 Canada Revenue Agency
Academic degree
Prerequisites
The academic degree Master of Laws (LL.M.) is conferred on all graduates in accordance with the rules and regulations of the Austrian University Act. This is conditional upon presentation of complete academic records for all program courses, as well as a positive assessment of the master thesis.
Credits
Students who can provide evidence of a sufficient and comparable level of knowledge in a particular field, either resulting from university education and/ or comparable education, may apply for accreditation of courses by the head of academic management.
Records of academic performance

Each course entails an assessment of academic performance on the basis of criteria laid down by the lecturers. This assessment consists of either a written or an oral exam on the course contents, and/or evaluation of performance in lectures, such as presentation of case studies or short presentations.
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Academic management
Prof. Michael Lang is the academic director of the program. As head of the Institute for Austrian and International Tax Law at the WU, he is aware of the steps required to achieve a high academic standard and a high degree of practical relevance in education. The underlying concept for this LL.M. program was developed by Prof. Lang and his colleagues at the Institute in close cooperation with the Akademie der Wirtschaftstreuhnder.
Doris Kucera, Wien
The academic team: Prof. Claus Staringer Prof. Michael Lang Prof. Josef Schuch
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Faculty
Aigner, Dietmar
Born in Linz in 1973. Studied business administration at the JKU (Linz) and the WU (Vienna University of Economics and Business) and law at the KFU (Graz). Before starting his academic career he worked for Deloitte. After he received his postdoctoral lecturing qualification in 2009 he became associate professor of tax management at the JKU (Linz). He has been cohead of the Institute for Tax Management since 2006 at the JKU and is a member of the Austrian branch of the International Fiscal Association (IFA) and the Austrian Chamber of Accountants. Dietmar Aigner is the author of several books and numerous articles on Austrian, European and international tax law and tax management. Austrian Tax Law, p. 29
Aujean, Michel
Graduated with an economics degree and masters degree (DES) from the faculty of law and economics, Paris in 1970. After teaching economics at the University of Pau in France, he joined the Directorate-General for Economic and Financial Affairs in the European Commission in 1976. Appointed as head of unit for VAT to the Directorate General for Customs and Indirect Taxation in 1988, he took responsibility for drafting and negotiating the EU transitional VAT regime. In 1994 Michel became director of Indirect Taxation. In 1998, he became director of Tax Policy to the Directorate General Taxation and Customs Union. Michel was then responsible for the Tax package initiative that includes Code of Conduct on Harmful Tax Competition and the Savings Directive. In 2004, Michel took responsibility for the Analyses and Tax Policies Directorate, which deals with general tax policy initiatives and specifically with direct tax matters (company and personal income tax) and also includes application of EU law and infringements. He was notably in charge of preparing the proposals for a Common Consolidated Corporate Tax Base and in 2006 he also promoted a new EU initiative on the coordination of tax s ystems within the EU. Michel is a member of the Permanent Scientific Committee of the IFA, has given tax law courses as visiting professor in the United States, France, Italy and Austria, and has spoken at many international conferences. Michel has published numerous articles on economics and taxation. In November 2007 he retired from the EU Commission and from 2008 he joined Taj Socit davocats member of Deloitte Touche Tohmatsu as partner-in-charge of Tajs Corporate Taxation Think Tank. Principles of European Tax Law, p. 41
of Fiscal Documentation) in Amsterdam, and was a visiting professor at the London School of Economics. He is consulting editor of the journal British Tax Review, a member (and past chairman) of the Tax Law Review Committee and a member of the steering committee of the UK Tax Law Rewrite. Tax Treaty Interpretation, p. 34
Avi-Yonah, Reuven S.
Graduated summa cum laude from the Hebrew University in 1983. In 1986, he received a PhD in history from Harvard University, followed by a JD magna cum laude from Harvard Law School in 1989. He is Irwin I. Cohn professor of law at the University of Michigan Law School and director of the International Tax LLM Program at this University. He has served as a consultant to the US Treasury and the OECD on tax competition issues, and has been a member of the Executive Committee of the New York State Bar Association Tax Section, as well as of the US Income Advisory Board. Since 2008, he is a fellow of the American Bar Foundation; since 2007 senior fellow at the Taxation Law and Policy Research Institute at Monash University. Since 2005, he is member of the steering group of the OECD International Network for Tax Research. He is the author of several books and numerous articles. Controlled Foreign Corporation Rules: Selected Contemporary Issues, p. 43
dArcy, Anne
Born in Frankfurt/Main in 1968, she completed her degree in business administration at the Goethe-University Frankfurt in 1993. She has been a university assistant and lecturer at the Department of International Accounting at the University of Frankfurt since 1998 where she also received her PhD in accounting. As head of European Accounting & Disclosure Regulation of Deutsche Bank AG, she was responsible for coordinating the companys annual and interim reports. Her professional experience also includes a position in the Listing Department of Deutsche Brse AG. From 2006 to 2010, she has held a position as full professor for financial accounting at the University of Lausanne, HEC. Before this appointment, she gained considerable academic experience lecturing at the Justus Liebig University Gieen and the WHU Otto Beisheim School of Management, Koblenz. Besides serving as regulator and standard setter, Anne dArcy has published in the field of international and comparative accounting and corporate go ernance. From June 2010, she holds a v chair in Corporate Governance and Management Control at the WU. IAS and IFRS, p. 47
Baconnier, Robert
Graduate of the Department of Political Sciences in Paris and of lEcole Nationale dAdministration. From 1979 to 1983, he was deputy director of the international division of the Tax Legislation Department, and until 1986 head of the Litigation Department in the Taxation Directorate. From 1986 to 1989 he was head of the Inland Revenue, and paymaster general until 1991. Since 1991, Mr. Baconnier has been chairman of the management board of Bureau Francis Lefebvre. He is now the chairman of Association Nationale des Socits par Actions, a professional association representing the issuers of securities on the financial markets. Tax Planning in France, p. 37
Avery Jones, John F.

Born in 1940 and graduated from Cambridge University. He is a judge of the Upper Tribunal (Tax and Chancery Chamber). He was chairman of the British Branch of the IFA, as well as member and vice-president of the IFA Executive Committee, and is a past chairman of the Board of Trustees of the IBFD (International Bureau
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Baker, Philip
Since 1998, visiting professional fellow at the Centre for Commercial Law Studies, Queen Mary, London University and joint head of the School of Tax Law. Since 1987, barrister, Grays Inn Tax Chambers, specializing in Revenue Law. He is a member of the UK Branch of the International Fiscal Association (IFA), and of the International Tax Sub-Committee, Law Society of England and Wales as well as of the Chartered Institute of Taxations, Education Committee and International Taxation Sub-Committee. Tax Treaty Interpretation, p. 34
consultant in 2003. He finished his teaching thesis about cross-border mergers in 2007. In 2009 he became head of the Department o f General Business Administration and Tax M anagement/Auditing at the Ilmenau University of Technology. He is the author of several books, including international tax law, and numerous articles on business taxation. Qualification Conflicts and International Tax Planning, p. 37
Daly, Michael
Head of the Asia-Pacific Section in the Trade Po icies Review ivision l D of the World Trade Organization since 1997, with esponsibility r for conducting periodic reviews of Members trade and trade-related policies, including taxation and tax measures. Concurrently, visiting scholar and fiscal expert in the Fiscal Affairs Department of the International Monetary Fund. After obtaining his doctorate in economics (specializing in public finance) from Queens University in Canada, he joined the Canadian Government, where he became senior economist at the Economic Council and was then chief of tax measures in the Tax Policy and Legislation Branch of the Department of Finance until 1990. From 1990 to 1992, he was an adviser at the European Commission, where he also served as secretary to the (Ruding) Committee on Company Taxation. Subsequently, he held the post of principal economist at the OECD, and was attached to the group negotiating the Multilateral Agreement on Investment, with responsibility for related tax matters. He has published articles on taxation, trade and other subjects in various academic journals. WTO and Tax Policy, p. 46
Brauner, Yariv
Born in Israel in 1969. Graduated from the Hebrew University, and earned an LLM (in international taxation) and a JSD from New York University. He is a professor of law at the University of Florida Levin College of Law. His research focuses on the merits of international cooperation and coordination of tax policies, and on the theory of corporate taxation. He is a co-author of a casebook on US international tax law and numerous articles published both in and outside the United States. US CFC, LOB and other Anti-Avoidance Rules, p. 44
Barkoczy, Stephen
He is a professor in the faculty of law at Monash University. He has been a consultant to one of Australias major law firms, Blake Dawson, for many years and has held positions as chairman of the Law Institute of Victorias Tax and Revenue Committee and principal examiner of its Tax Law Specialisation Program. Stephen is a former editor of the Journal of Australian Taxation and the author/co-author of many taxation textbooks, including Foundations of Taxation Law, Australian Taxation Law, Australian Tax Casebook, Government Venture Capital Incentive A Multi-Jurisdiction Comparative Analysis and Pooled Development Funds Handbook. Stephen is a recipient of Monash Universitys Vice Chancellors Award for Teaching Excellence and a recipient of an Australian Learning and Teaching Council Award for Teaching Excellence. In 2008, he received the Prime Ministers Award for Australian University Teacher of the Year. Australian Tax Law, p. 29
Brooks, Neil
Professor Neil Brooks has taught tax law and policy at Osgoode Hall Law School in Toronto for over 35 years and is director of the Graduate Program in Taxation. He has published extensively on income tax issues and has been editor of Canadian Taxation, Osgoode Hall Law Journal and the Canadian Tax Journal. He has been a consultant on tax policy and reform issues to several departments in the government of Canada, and to the governments of New Zealand, Australia, and several Canadian provinces. He was co-vice chair of the Ontario Fair Tax Commission and has been on several advisory committees for the Auditor-General of Canada and Revenue Canada. Over the past few years he has participated in capacity-building projects relating to the income tax in a number of primarily low-income countries including Lithuania, Vietnam, Japan, China, Mongolia, South Africa, Bangladesh, Ghana, Zimbabwe, and Sri Lanka. Comparative Tax Law, p. 30
De Broe, Luc
Born 1959, graduated from the Katholieke Universiteit Leuven (lic. jur., K.U.Leuven, 1982). He obtained a master of laws (LLM) degree from the Northwestern University School of Law (Chicago, 1986). He obtained a degree in tax law from the Ecole Suprieure des Sciences Fiscales Bruxelles (1987) and obtained his doctorate degree at Katholieke Universiteit Leuven. Admitted to the Brussels Bar in 1982. Partner in the Brussels office of Stibbe since 1997 and of-counsel since 2005. Professor of tax law, Katholieke Universiteit Leuven (2007). Since 2007, Luc De Broe is a member of the executive committee of the IFA. Luc De Broe is the author of numerous articles on Belgian, international and European tax law; of a manual on cross-border leasing between Belgium and the United States (for which he was awarded the Mitchell B. Carroll Prize of IFA, 1988); a manual on mergers and divisions of Belgian
Brhler, Gernot
Born in 1972 in Dsseldorf, Gernot Brhler studied business administration at the Catholic University of EichstttIngolstadt and received his doctorate in 2001 with a thesis on German direct investments in the USA. After 1 years of practical work at a tax company, he became a certified tax
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enterprises (1993) and a dissertation on International tax planning & prevention of abuse under domestic tax law, tax treaties & EClaw. A study of the use of conduit & base companies. Limits to Tax Planning from a Perspective of Community Law, p. 50
Edgar, Timothy
He is a professor of tax law at Osgoode Hall Law School, York U niversity, Toronto and of the aculty of law, the f University of ydney. S Before that, he was an associate with Stikeman, Elliott in Toronto. He has also served as a consultant to the Department of Finance, the Canada Revenue Agency, the Auditor eneral, the nternational G I Mo etary Fund, the rganization for conomic n O E Co-operation and Development, the Australian Treasury Department, and the Australian Taxation Office. He was also a senior policy advisor with the Policy Advice Division of New Zealand Inland evenue. rofessor Edgar has R P published numerous articles in the Canadian Tax Journal and other periodicals and is a c o-editor of the Current Tax eading feature R of the journal. He is the author of The Income Tax Treatment of Financial Instruments: Theory and Practice. Financial Instruments in International Tax Planning, p. 36
Eichenhofer, Eberhard
Born in 1950, he stu ied d law and olitical scip ences at the niversity U of Tbingen and Saarbrcken. Since 1997, he holds the chair in labor law/social security law/civil law at the Friedrich-Schiller-University of Jena. He works frequently as an expert on problems of oordination of social security for the EU c Commission and national institutions. His lectures at the University of Jena are focused on German and European civil, labor and social security law. His publications concentrate on German, European and international social security law. He is the German representative within the European Institute of Social Security. International Social Security Law, p. 47
Dunahoo, Carol
She is partner of Baker & McKenzie, Washington and specializes in international tax controversies, compliance, and planning. Most recently, Ms. Dunahoo served as the US competent authority and director, international at the US Internal Re enue Service. She also previously served v as associate international tax counsel at the US Department of the Treasury, where she negotiated new treaty agreements with C anada, France, Germany, and Portugal, handled matters involving other treaties, and worked on guidance, legislation, and itigation l regarding a variety of international tax issues. She was selected for inclusion in the 2005 and 2006 editions of The Best Lawyers in America. She is a member of the Executive Committee of the IFA. Conflict Settlement in Tax Treaty Law, p. 32
Eilmansberger, Thomas
Thomas Eilmansberger is full professor at the Department for Labour, Economic and uropean E Law at the University of Salzburg. Before r eturning to the Law Faculty in alzburg in S 2000, he was a Fulbright visiting professor at Southwestern University School of Law, Los Angeles. Prof. Eilmansberger also served as resident counsel for the inter ational law n firm Bruckhaus Westrick Heller Lber (now Freshfields Bruckhaus Deringer) in Brussels. He was a member of the Austrian Federal Procurement Review Commission, as well as a member of the group of experts advising the erman government on the reform of the G GWB (German competition law). Prof.Eilmansberger also advised the Hungarian Energy Office regarding the application of EC competition and regulatory law to long-term power purchasing agreements. More recently, he has acted as special advisor to EU Commissioner Vivienne Reding regarding the review of the regulatory framework for electronic communications. Furthermore, Prof. Eilmansberger has been representing the European Commission in proceedings before the Court of Justice on a regular basis (currently in case T-406/09, Donau Chemie AG v Commission). He is the author of several books and numerous articles on European economic law. EU State Aid Rules and Taxation, p. 41
Ehrke-Rabel, Tina
Born in Graz in 1975. After receiving her postdoctoral lecturing qualification in 2005, she worked as an adviser at BDO Graz and now is a partner of BDO Graz. From January 2009 to March 2010, she was a part-time professor of tax law at the Institute of Fiscal Law, Tax Law and Tax Politics at the University of Linz. Since March 2010, she is a professor of tax law at the University of Graz and the head of the Institute for Fiscal Law at this university. In her research Tina Ehrke-Rabel focuses on EU tax law, VAT and tax procedure on both an international and national level and constitutional questions of taxation. She is responsible for articles on tax procedure of the scientific journal TAXLEX and for indirect taxes at European Law Reporter. She is a member of IFA and a member of the European Association of Tax Law Professors (EATLP). Austrian Tax Law, p. 29
Eberhartinger, Eva
Born in Linz in 1968, she completed her degree at the WU in 1994, and then followed a postgraduate course in european legal stu ies d at the University of Exeter. After gaining practical experience in a tax consultancy and in the European Parliament, Ms. Eberhartinger became a university assistant and lecturer at the Department of Auditing and Accounting at the WU, a position she has held since 1992. In addition to drawing up auditors opinions, she also has many publications in the fields of taxation, accounting, corporate taxation, and international tendering. In 1999, she achieved a tenured position. At the beginning of 2000, she held a position as a visiting professor at the HEC, Paris. From 2000 until 2002, she was full professor at the University of Mnster, Germany. Since 2002, she holds a chair in tax management at the WU. IAS and IFRS, p. 47
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Englisch, Joachim
He studied law at the Universities of Saarbrcken, Salamanca, and Cologne. He graduated with a major in tax law and he has also received a pre-diploma in business administration. After raduating, g he served as a clerk in various positions of the German judicial system for two years. He then became a research ssistant and ubsequently a s an assistant rofessor at the Institute for p Tax Law of Cologne niversity. In 2004, he U completed his PhD on dividend taxation. In 2007 after a period as research ellow of the f Deutsche Forschungs emeinschaft, r.Engg D lisch was bestowed with a ius docendi in tax law, public law, and European law upon defending his habilitation thesis on quality e of competition in cross-border trade. From January 2008 to March 2010, he acted as full professor for tax law and public law at the U niversity of Augsburg. Since April 2010, Dr. Englisch holds a chair for tax law and p ublic law at the Tax Law Institute of uenster M U niversity and will become its managing d irector in 2011. His main fields of research are European tax law in the area of direct taxation, and the harmonized system of VAT. He has published various books and articles on these and other tax topics and he has lectured extensively both nationally and internatio ally. n Currently, he is supervising several doctoral theses on European Taxation and VAT issues. Dr. Englisch also acts as an academic advisor for the Consumption Tax Unit of the OECD and as a member of the editorial advisory boards of several national and foreign tax journals. Dr. Englisch is a member of IFA, the EATLP, the Group for Research on European and International Taxation (GREIT), the German VAT Forum, the German Association of Tax Law Professionals (DStJG; member of the Scientific Committee), and of the Association of German Public Law Professors (VDStRL). He is acting president of the Westfalian Forum for Tax Law. Tax Planning in the Context of European Tax Directives, p. 38
Essers, Peter
Studied fiscal cono ics e m at Tilburg niversity, U the Netherlands. He is professor of tax law at Tilburg niversity, U s pecializing in national and international p ersonal and corporate income tax. He is director of the European Tax College and oordinator of EUCOTAX (European c U niversities Cooperating on Taxes). He has been visiting professor at the Universit P anthon-Sorbonne, the University of Bologna, Universidad de Barcelona, the University of Osnabrck, Northwestern University Chicago, LUISS University Rome and the WU. He is also member of the Dutch Senate and chairman of the Finance Committee of the Senate. Tax Law of the Netherlands, p. 31
Commentario, 2002, Aspetti internazionali della riforma fiscale, Milan 2004. Author of Manuale di tassazione internazionale, Milan, 2008, and of three monographs, as well as of about seventy publications on Italian, comparative and international taxation. Comparative Corporate Tax Policies, p. 44
Garca Prats, F.Alfredo

Born in Castelln, in 1966. Doctor in law with extraordinary honors (1994) with his thesis on permanent establishments in international tax law. Professor of financial and tax law at the University of Valencia (Spain) since 1997; visiting professor at the Universi ies of t London, Harvard, Leiden, Leuven, Bergamo, Bocconi, Salamanca and Toledo, rof.GarP ca Prats specializes in international tax law, EC tax law and tax principles. Observer and adviser of the Ad Hoc Group of Experts on International Cooperation in Tax Matters of the United Nations since 1995 and of the F iscal Committee of the United Nations since 2005, senior counsel at the IMF in 2008, member of the scientific committee of iffe ent tax d r and international tax journals. Permanent Establishments, p. 33
Garbarino, Carlo
Carlo Garbarino is professor of taxation at Bocconi University, Milan, member of Dipartimento di Studi Giuridici and of Steering Committee of the PhD Program in International Economic Law of the same university, and affiliated member of the Department of Accounting, Bocconi. Member of the Steering Committee Research Department SDA Bocconi. PhD in comparative and international taxation, master of laws at the University of Michigan, visiting scholar at Yale University Law School and visiting professor at Universit Sorbonne-Paris, University of Michigan Law School, University of San Paulo. Member of the Faculty of Scuola Direzione Aziendale (SDA) Bocconi, of International Network for Tax Research OECD, Paris, and of Tax Committee-American Chamber of Commerce. Member of the Editorial Board of Alta Scuola Formazione ODC, Milan, coordinator of Comitato Tecnico Internazionale at Bocconi University, director of Osservatorio Fiscale e Contabile SDA Bocconi, editor of EC Tax Review, Economia & Management SDA, Diritto tributario internazionale; editorin-chief of Fiscalit Internazionale, director of the Series Comparative and International Taxation, Bocconi University Press Egea, Milan; editor of four volumes: Aspetti fiscali delle operazioni internazionali, 1995; Convenzione Italia-USA contro le doppie imposizioni. Commentario, 2001; Le Convenzioni dellItalia in materia di imposte su reddito e patrimonio.
Gustafson, Charles
Professor of law at the Georgetown University Law Center in Washington, DC. He lectures in various areas of public international law, international trade and investment, and federal taxation, and recently completed five and a half years of service as the associate dean for international and graduate programs. He is a co-author of several casebooks on federal income taxation, including Taxation of International Transactions, as well as articles on issues of international law and taxation. He has practiced in New York and Washington, served in the Office of the Legal Adviser to the Department of State and lectured at universities on every continent. He spent several years as a member of the faculty of law at Ahmadu Bello University in Nigeria. He has also served as consultant to various United States Government agencies and to several international organizations, as well as arbitrating in commercial and nvestment i
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disputes. He is an active member of the American Law Institute and has served on a number of committees for the American Bar Association. He received his JD degree from the University of Chicago and his BS degree from the University of Buffalo. Tax Treaties between Developed and Less Developed Countries, p. 34
Gnther, Oliver-Christoph
Oliver-Christoph Gnther was born in Vienna in 1984. After his taking his degree in Business Studies (Business Diploma) and Business Law (Bachelor of Laws) at the WU, he became research and teaching associate at the Institute for Austrian and International Tax Law at the same university in August 2008. Mr. Gnther has published a number of essays and articles and lectured on numerous occasions on national and international tax law. Exchange of Information Seminar II and III, p. 48
Hellio, Francois
Graduate of the French Business School HEC (1988) with a masters degree in law (1992). From 1993 to 1998, he was tax lawyer at the French desk of Bureau Francis Lefebvre in Berlin. Since 1993, he has been a lawyer in the international tax division of Bureau Francis Lefebvre in Paris. He is now tax partner at CMS Bureau Francis Lefebvre. He is co-author of Steuern in Frankreich, a book published in Germany and dedicated to French taxation. Tax Planning in France, p. 37
Gutmann, Daniel
Daniel Gutmann is a professor of tax law at University Paris-1 Panthon-Sorbonne. He specializes in International and Comparative Taxation, a field in which he wrote numerous articles for international and domestic tax reviews. He also wrote a book on international private law. In addition to his academic activities, Daniel Gutmann is an of-counsel with CMS Bureau Francis Lefebvre, as well as an independent counsel for various private and public institutions. He also acted as a consulting counsel with the IMF Legal Department, specializing in technical assistance in tax legislation (Washington DC, January-July 2006). This provided him with an opportunity to draft tax legislation on individual and corporate income tax, tax proceedings and oil funds. He was a member of the European Commission Workshop of Experts on Tax Treaties and EC Law (July 2005) and is still active in the ECJ Task Force of the Confdration Fiscale Europenne. Daniel is one of the founders and the present scientific director of the French Institute for Tax Policy, whose goal is to provide for independent advice for tax policy-makers in France. He is also one of the founders and directors of Lanne fiscale, a French tax review with a focus on international tax questions. He is a member of the executive board of the EATLP. He was appointed professor in 1997 after his PhD. He graduated from the Ecole des Hautes Etudes Commerciales (HEC, 1990) and he obtained two DEA in private law and in legal philosophy (postgraduate degrees) in 1991 and 1992 at the University of Paris II. French Tax Law, p. 30
Henze, Thomas Harris, Peter A.

He is a lawyer whose primary academic interest is in international, corporate and comparative tax law, its history and development. Dr.Harris is a reader at the faculty of law of the University of Cambridge and a tutor and fellow of Churchill College. He is the author of four international tax books and many refereed articles. He has worked for more than 11 years as an external technical assistance advisor for the legal department of the International Monetary Fund where he assists in drafting tax laws for developing countries. He has taught as a visiting professor at Georgetown, Sydney, Leiden, Utrecht, Paris, Florida, Pretoria, Auckland, London, and Oslo. Dr. Harris consults on an ongoing basis for KPMG, largely in the d elivery of its training program. Controlled Foreign Corporation Rules: Selected Contemporary Issues, p. 43 Born 1965 in Hannover (Germany). After studying law and European legal practice at the Universities of Gttingen, Rouen, and Hannover and after his practical legal training (Referendariat), he joined the German Federal Ministry of Economics and Technology (Legal Service, later Section for the Electricity Supply Industry) in 1998. From 2001 to 2010, he worked as legal secretary (rfrendaire) at the Court of Justice of the European Union, first in the chambers of Advocate General Siegbert Alber (2001 2003), and later in the chambers of Advocate General Juliane Kokott (2003 2010). In May 2010, he returned to the German Federal Ministry of Economics and Technology and became head of the division responsible for EU Litigation. Thomas Henze mainly works on cases concerning VAT and direct taxation. He has been teaching ECJ procedural law and the Courts recent case law at the Deutsche Richterakademie (German Judges Academy) and the Bundesfinanzakademie (Federal Finance Academy). ECJ Case Law, p. 40
Heerdt, Tobias
Born in 1979, studied business administration at the Catholic University of Eichsttt-Ingolstadt in Germany and graduated in 2005. Since 2005, he is research associate at the chair of business taxation at the Catholic University of Eichsttt-Ingolstadt. He joined the tax department of Ernst & Young in 2005 and works in the international tax services practice. His main focus in academics and in practice is on the tax impact of M&A activities. Qualification Conflicts and International Tax Planning, p. 37
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Heydt, Volker
Born 1942 in Hamburg, legal studies in Hamburg and Mnster; second state examination 1968 in Berlin. 1968 1972 assistant to Prof. Blck at the Speyer Postgraduate Administration School, 1972 1973 second secretary to the Legal Affairs Committee of the Parliamentary Assembly of the Council of Europe in Strasbourg, 1973 1977 director of studies at the Gustav Stresemann Institute. From 1978 until retirement in 2007, official of the European Commission in Brussels, dealing in different units with taxation and financial institutions. From 1998, and from 2004 as head of unit, in charge of monitoring the application of Union law in the field of direct taxation in the Commissions Directorate General Taxation and Customs Union. Since 2009 member of the Hamburg Bar. Trends in EU Tax Law, p. 45
division in 2007. As head of the Austrian delegation, he has negotiated many double taxation conventions and is a leading figure in the organization of international administrative assistance and reporting procedures. He also represents the ministry in international organizations and acted as vice-chair of working party 8 of the Committee on Fiscal Affairs for many years. In addition, for many years he is a lecturer at the Tax Academy of the Financial Administration. Numerous publications on international tax law. Abuse of Tax Treaties, p. 43
Kana, Liselott
Born in Stockholm in 1955, she graduated from Stockholm University with a bachelor of law degree and went on to receive a master of law at the London School of Economics in 1984. Since 1990, she has been involved with international issues in Chile, at the Ministry of Foreign affairs and then at the Ministry of Finance. In 1997, she was appointed head of international taxation in charge of negotiating taxation treaties. She teaches international taxation at the Catholic University in Santiago and is a member of the United Nations group of tax experts. South American Tax Treaty Policy, p. 33
Jochum, Heike
Born in Rodalben in 1968. After receiving her postdoctoral lecturing qualification in 2004 at the Saarland University, she became professor of tax law with a focus on German and European tax law at the University of Osnabrck. She has been head of the Institute for Finance and Tax Law since 2006, as well as responsible for the LLM Program Taxation at the University of Osnabrck. Mrs. Jochum has published numerous articles in various approved scientific journals. She is a member of the IFA and of the EATLP. In 2010, she was chosen as dean of the law faculty at Osnabrck. German Tax Law, p. 30
Kemmeren, Eric
Born in Dongen (the Netherlands) in 1963. As of 2002, he is p rofessor of international taxation and international tax law at the Fiscal Institute Tilburg of Tilburg University in the Netherlands. As of 1992, he is also of-counsel with Ernst & Young Tax Advisers, and as of 2007 he is also a deputy justice of the Arnhem Court of Appeals (Tax Division), the Netherlands. Before he joined Tilburg University in 1991, he was a tax inspector (corporate and income tax) for 4 years. In 2001, he obtained his PhD from Tilburg University on a thesis entitled Principle of Origin in Tax Conventions, A Rethinking of Model. He is an editor of the EUCOTAX Series on European Taxation and EC Tax Review published by Kluwer Law International. Furthermore, he is a coinitiator and coordinator of the European Tax College (a joint Advanced Master in European and International Taxation of KU Leuven and Tilburg University), the EUCOTAX Network, and the EUCOTAX Winter Course. He was also a visiting scholar at New York University (spring 1999). He regularly gives guest lectures at foreign universities (visiting professor, inter alia, at Universit Panthon-Sorbonne (Paris-I), France and Northwestern University (Chicago), USA, LUISS (Rome), Italy) and is a frequent speaker at international congresses, seminars, and courses. He was and is a member of various academic and non-academic commissions. Tax Treaty Developments: Source versus Residence Principle, p. 34
Hohenwarter-Mayr, Daniela
Born 1980 in Vienna, she graduated with excellence from the WU in 2003. After completing the Vienna Postgraduate Program in International Tax Law in 2004 she joined the Institute for Austrian and International Tax Law at the WU as assistant professor and has lectured there since 2006. In 2009 Daniela Hohenwarter-Mayr earned her doctorate in law with a thesis on The Compensation of Losses in Groups of Companies. Her research and publishing activities mainly focus on international and European business taxation. Tax Consequences of Mergers in Europe, p. 37 Trends in EU Tax Law, p. 45
Kalss, Susanne
Born in St.Martin/Grimming (Styria) in 1966. After receiving her postdoctoral lecturing qualification in 2000 at the University of Economics, Vienna, she became professor of private law at the University of Klagenfurt (Carinthia) in the same year. In 2003, she became professor of private and commercial law at the WU. In 2000, Prof. Kalss won the START-Prize for her research project Law of companies with limited liability, sponsored by the Austrian Science Fund. European Company Law, p. 46
Jirousek, Heinz
Born in Vienna in 1949, he completed his studies in law in 1972. In that year, he also entered the Austrian financial administration, joining the International Tax Law Division of the Federal Ministry of Finance in 1975 and becoming head of this
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Kersting, Christian
Born in 1971. Studied law in Bonn, Lausanne and Geneva, awarded doctoral degree in 2000 (Bonn) and LLM in 2002 (Yale). Senior research fellow at the Max Planck Institute for Intellectual Property, Competition and Tax Law (2002 2006). Received his postdoctoral qualification in 2006 (Munich). Visiting professor at Lausanne (Summer Term 2007). Since 2007, professor at Dsseldorf University (Chair of Civil Law, German and International Business Law, Antitrust Law). Research interests include civil law, German and European commercial law, company, accounting and capital markets law, comparative law, tax law, antitrust law. European Company Law, p. 46
Federal Ministry of Finance and as an assistant professor at the University of Linz and is now professor of tax law at the University of Linz. He serves as a member of the scientific staff of or correspondent for several business and tax law journals and has published widely on issues of Austrian, international and European taxation. Tax Planning in the Context of European Tax Directives, p. 38
Lejeune, Ine
Born in Oostende in 1961, Ine is the Global Indirect Taxes Network Leader at PricewaterhouseCoopers, responsible for leading a network consisting of over 2000 PwC experts based in 130 countries. Ine is the partner responsible for PwC tax and legal services to the European Commission (Directorate General for Taxation). Besides a law degree, Ine holds a degree in tax sciences with special prize for international taxation, which she received in 1986. Ine has led 19assignments for the EU Commission, including the two studies which were followed by EU directives and also has extensive experience in indirect tax policy design and reform programs, working with tax administrations in several jurisdictions (the Middle East, China, India, and Belgium). She has been a guest professor on indirect taxes at Antwerp University from 1996 up to 2004 and she is co-business chair of the OECD Informal Consulting Group on Tax Electronic Audits since 2005. She is a recognized tax adviser and member of the Belgian Institute of Accountants and Tax Advisers (Instituut van Accountants en Belastingconsulenten/Institut des Experts-Comptables et des Conseils Fiscaux (IAB/IEC)) and the IFA. In 2006, Ine was elected as the 5th Global most influential tax expert by Tax Business (November/December 2006, issue 16) and the first indirect tax expert. She received the Belgian TaxMan of the year 2009 Award. She has published several practical guides on VAT and many articles. She published books on e-Invoicing & e-Archiving (2006) and the EU Enlargement (2004). She has been the editor of PricewaterhouseCoopers A Guide to VAT in the EU since its first appearance in 1993. VAT Planning, p. 39
Krenzin, Andreas
Born in 1981 in Donauwrth and studied business administration at the Catholic University of Eichsttt-Ingolstadt. Afterwards he worked several years at a German tax firm where he focused on international tax planning as well as on reorganizations and restructurings. In 2009, he became research assistant and doctoral candidate at the Catholic University of Eichsttt-Ingolstadt. In March 2010, he successfully passed the German tax consultant exam. Qualification Conflicts and International Tax Planning, p. 37
Kessler, Wolfgang
Born in 1956 in Offenbach, received his doctorate from the University of Aachen in 1989. He has been a certified tax consultant since 1991. He specializes in corporate tax law and international tax law. He is director of both the Institute of Business Taxation at the Albert Ludwig University in Freiburg and the Zentrum fr Business and Law, which offers, among other things, a postgraduate MBA in International Taxation and a Master of Taxation. In addition, he is a partner with Ernst & Young Germany in charge of national tax training where he has implemented modern means of communication such as web-based training (WBT), webcast and e-Learning. Holding Companies and Tax Planning, p. 36
Lang, Michael
Born in Vienna in 1965. After receiving his postdoctoral lecturing qualification in 1992, he became professor of tax law with a focus on international tax law at the WU. He has been head of the nstitute for I Austrian and International Tax Law since 1998, as well as responsible for the LLM rogram p in international tax law at the WU. Prof. Lang has been editor of the scientific journal SWI (Steuer und Wirtschaft International), and was a partner with Deloitte until 2004. He was a member of the Permanent Scientific C ommittee (PSC) of IFA and is still a member of the Executive Committee of the EATLP and chairman of the Academic Committee of the EATLP. Principles of Tax Treaty Law, p. 33
Kofler, Georg
Born in Linz in 1977. Georg Kofler earned a doctorate in law as well as a doctorate in business administration in 2002 and 2003, respectively, and an LLM in international taxation from New York University in 2004. In 2006, he received his postdoctoral lecturing qualification with a thesis on Double Taxation Conventions and European Community Law. He has worked with the International Department of the Austrian
Loukota, Helmut
Born in 1940 and received his doctors degree from the University of Vienna in 1962. In that year he also joined the Austrian tax administration. In 1988, he was appointed director of the Division for International Tax Law in the Ministry of Finance and also acted in that capacity as head of the Austrian delegations in the Austrian tax treaty negotiation process. In the course of his work for the OECD he was vice chairman of the
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OECD Working Party on Double Taxation and chairman of the Working Group on Partnerships. He is the author of several books and numerous articles, gives lectures at universities, at the OECD Tax Training Centre in Vienna, and at the Austrian Federal Tax Academy. In 2000, he became honorary professor. After his retirement at the end of 2006, he continued his work for the Ministry of Finance as an independent consultant in international tax matters. Abuse of Tax Treaties, p. 43
Malherbe, Jacques
Jacques Malherbe is a professor emeritus of law of Louvain University and a partner in the Brussels law firm of Liedekerke. He holds a doctorate in law and a degree in economic sciences of the Catholic University of Louvain (UCL) and a master of laws (LLM) of Harvard University. His publications include the Business Operations in Belgium Portfolio (BNA) and leading textbooks on Belgian corporate law, international taxation and Belgian corporate tax. He frequently makes speeches on international corporate and estate taxation and has written a number of articles in the field. He recently directed a study at the request of the European Parliament on The Impact of Tax Rulings of the European Court of Justice on Direct Taxation. Jacques Malherbe teaches European financial and tax law at various universities (Louvain, EDHEC, WU, Hamburg, Bologna, and Castilla-La Mancha). Belgian Tax Law, p. 29
Michielse, Geerten
Born in 1960; worked as a tax consultant specializing in international taxation matters before completing his postdoctoral lectu ing qualificar tion on the ubject of s Thin capitalization in international tax law. Michielse is professor in tax law, director of the Center for Taxation and Public Governance in Amsterdam (the etherlands), N and advisor to the IMF/World Bank Group in Washington DC. He has given guest ectures l at a number of European universities and f ulfills an advisory role for several foreign financial administrations. Comparative Tax Law, p. 30
Lthi, Daniel
Daniel Lthi, born in 1936, graduated from the Universities of Bern and Geneva. He joined the Swiss Federal Tax Administration in 1968. From 1980 to the end of 1998, he was head of the Division for International Tax Law and Double Taxation Matters. Since 1999, he is practicing as an independent consultant. Furthermore, until February 2001, he chaired the OECD Working Party No. 1 on double taxation. He now is a member of the OECD Advisory Group in international tax matters. Until recently he was the ad-personam expert of Switzerland in the United Nations Ad Hoc Group on International Cooperation in Tax Matters. The Negotiation of Tax Treaties, p. 35
Nakhai, Katja
Katja is a Senior Mana er in the Gerg man International Tax Inbound Service Line and based in Munich. Katja joined Deloitte in 2000; she has over ten years of experience, advising numerous private equity and corporate investors in tax due diligence and tax structuring projects for German cquisitions. She also advised on the a tax aspects of reorganizing and refinancing companies in distress in a number of cases. Other projects she was engaged in included advice to multinational clients regarding their inbound investments into Germany with a special focus on cross-border tax planning. Katja is a licensed German tax adviser and a frequent contributor to German and English language magazines including Tax Notes International and International Tax Review. She regularly speaks at conferences on v arious topics in international taxation. International Mergers and Acquisitions, p. 36
Massoner, Christian
Born in Villach in 1984. He completed his studies in business and law at the WU and the University of Alberta. In 2007, he became research associate at the Institute for Austrian and International Tax Law at the WU and has lectured there since 2008. His research focuses particularly on international tax law and business taxation. International Group Financing Seminar II and III, p. 49
Maisto, Guglielmo
Guglielmo Maisto founded Maisto e Associati in 1991. He is a professor of tax law at the Catholic University of Piacenza; he has acted as a consultant to the Ministry for European Community Affairs and is the chairman of the delegated board of trustees of the IBFD in Amsterdam. He is the chairman of the legal and tax committee of the American Chamber of Commerce in Italy and represents the Italian Association of Industries at the OECD Business Industry Advisory Committee in Paris. He is a member of several law societies internationally and of the editorial board of various Italian and foreign tax legal journals. He is a member of the EU Joint Transfer Pricing Forum and he has acted as general and national reporter at several annual congresses thereof. Holding Companies and Tax Planning, p. 36
Masui, Yoshihiro
Mr. Masui is professor of law at the University of Tokyo. He served as an expert member for the tax commission of the Japanese government (2003-2006) and was a member of the Permanent Scientific Committee of the IFA (1999-2009). His monograph Taxation of Corporate Groups (University of Tokyo Press, 2002, in Japanese) won the Institute of Tax Research and Literature Award. He received an LL.B. in 1978 from the University of Tokyo and an ITP/LLM in 1992 from Harvard University. Tax Planning in Japan, p. 37
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Nettinga, Margaret
Margaret is an American who has lived in the Netherlands since 1969. She is something of a hybrid, having completed degrees in history and anthropology in New York, and in law at the University of Leiden. From 1991 to 2005, she was a member of the research staff at the IBFD in Amsterdam, where she edited the monthly tax journal European Taxation. She is now working as a free-lance editor and translator and gives courses/training in legal and tax English. International Tax English, p. 47
Appeals Court for Social Security; since 2004, president of the Dutch section of the European Institute of Social Security. International Social Security Law, p. 47
Pistone, Pasquale
Born in 1968 in Naples, he graduated cum laude in law at the Federico II University of Naples in 1990, obtained his doctoral degree in 2000 cum dignitate publicationis at the University of Genoa with a thesis on community law and tax treaties and the 2005 EURYI Award of the European Science Foundation. He is associate professor of tax law at the University of Salerno and EURYI-ESF professor at the WU. His current research focus includes taxation in relations with developing countries, good governance and global fiscal transparency. He has been visiting professor at various universities and is a frequent speaker at international tax conferences around the world. He is fluent in seven languages, editor of fourteen books, author of two monographic studies and over one hundred tax articles written and/or translated in nine languages. EU and Third Countries, p. 40
Pickering, Ariane
Ariane has pursued a career in taxation for more than 30 years, working in the international tax law development and interpretation areas of the Australian Tax Office and in the Australian Treasury. She held the position of principal adviser treaties in the International Tax and Treaties Division of Treasury, with responsibility for deve oping l and implementing tax treaty policy, and negotiating Australias tax treaties. Until 2010, she was Australias chief tax treaty negotiator and main delegate to the OECDs working party on tax treaties Working Party 1 of the Committee on Fiscal Affairs. Since then, Ariane has been working as an independent consultant on international tax matters. Australian Tax Treaty Policy, p. 32
Ostwal, T.P.
Born in 1954, Ostwal is an economic graduate from India and a chartered accountant in practice since 1978. He is a senior partner of M/S T.P. Ostwal & Associates. Was a member of the CID TAG of OECD & BIAC. Vice president of the IFA and ex-chairman India branch. He has been appointed on several committees set by the Ministry of Finance and other ministries of the government of India. Was professor at the university of Mumbai. Is actively involved in handling international tax issues on crossborder transactions for a wide range of clients in India particularly in the field of technology and software and telecommunication industry etc. Co-authored Transfer Pricing Manual published in India. Was adjudged eleventh in the top 50 tax professionals in the world for the year 2006-07 by Tax Business magazine of the UK in November 2006. Indian Tax Law, p. 30
Rdler, Albert J. Pijl, Hans

Hans was a partner with Andersens and joined Deloitte in 2002. He is a part-time judge in The Hague Tax Court of Appeals, and was the non-governmental expert in the UN sub-group of experts for the definition of the PE-Article, which finished its work in 2010. Hans studied fiscal law (with honors) and linguistics at the Universities of Leiden and Groningen, and worked for the Netherlands Revenue Service and the Ministry of Finance. He is a lecturer at the International Tax Center Leiden and at the IBFD. Hans is a member of European Taxations board of editors. He has written numerous articles on international tax law. Transfer Pricing, p. 35 In 1960, obtained his doctorate at the University of Munich on the subject of corporate tax harmonization. He served as a lecturer at the University of Regensburg from 1966 to 1982, as well as head of the Ottmar Bhler Research Center for International Tax Law. He held a chair in international business taxation at the University of Hamburg from 1982 to 1998. In 1991/1992, he was member of the Ruding Committee appointed by the EU Commission. As well as being senior tax partner at Linklaters LLP in Munich, he is a member of the Scientific Committee of the CFE (Confdration Fiscale Europenne), the Association of European Tax Consultants, of which he was the chairman from 1984 to 1988. He is also member of several supervisory boards of both listed and unlisted companies. Tax Policies in the EU, p. 42
Pennings, Frans
Studied Dutch language and literature and Dutch law at Utrecht University. From 1990, he worked at Tilburg University, and since 2000 as professor of international social security law. In 2002, Pennings was appointed as professor of international social security law at Utrecht University. From 2008, he is working as full-time professor of labor law and social security at Utrecht University. Since 1994, he is judge in the Central
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Reimer, Ekkehart
Born in Bonn in 1969, legal studies at Heidelberg, Munich, and Speyer. From 1996 to 2005, research associate at the University of Munich, Research Center for European and International Taxation (with Prof. Klaus Vogel and Prof. Moris Lehner). Doctorate (Dr. iur.) with a thesis on taxation of income from inaction from a tax treaty perspective (IFA Mitchell B. Carroll Prize, 2004). Venia legendi with a habilitation thesis on conflict of interests from a constitutional and administrative law viewpoint in 2005. Since 2006, full-time professor at the University of Heidelberg (Institute for Finance and Tax Law, chair for European and International Taxation). Since 2009, part-time judge at the High Administrative Court of Baden-Wrttemberg. Publications on tax treaty law, European tax law and selected issues of domestic tax law. The Relevance of OECD Documents for the Interpretation of Bilateral Tax Treaties, p. 35
Rosenbloom, H.David
Born in 1941, he received a JD magna cum laude from Harvard Law School in 1966, where he was president of the Harvard Law Review. A partner of Caplin & Drysdale in Washington DC, he is also director of the International Tax Program at New York University School of Law. He has taught at Harvard, Stanford, Columbia, and the University of Pennsylvania Law Schools, and been a visiting professor at University Commericale Luigi Bocconi, the University of Bergamo, the Universities of Sydney and Melbourne, Leiden University, and the Universities of Mainz and Heidelberg. He is the author of numerous publications on international taxation. Tax Planning in the US, including Transfer Pricing, p. 39
Rust, Alexander
Born in 1973. He stu ied law with a d s pecialization in tax law in Freiburg (Breisgau), Geneva and Munich. During his Referendariat (legal traineeship) he worked as an assistant judge and as a ublic p p rosecutor at the High Court of Munich, as a law clerk at the Ministry of Finance and as a tax advisor in private practice. In 2001 he was appointed assistant professor at the University of Munich, in 2008/2009 he worked as acting assistant professor at New York niversity. U Since 2010 he is associate professor for tax law at the University of Luxembourg. His PhD thesis on the compatibility of CFC legislation with tax treaty and EC law won the European Academic Tax Thesis Award. Alexander Rust is specialized in international tax law as well as European tax law. German Tax Law, p. 30
Russo, Raffaele
Is an advisor with the OECD Centre for Tax Policy and Administration (Paris), where he leads the work on aggressive tax planning. Before joining the OECD, he was a senior associate at the International Tax Academy of the IBFD and a tax lawyer with NCTM Studio Legale Associato (Milan). Rafa is the author of several articles on international tax matters and editor and chief author of the books The Attribution of Profits to Permanent Establishments: The taxation of intra-company dealings (2005) and Fundamentals of International Tax Planning (2007). He has published articles in Italian, English, and Spanish. His articles have also been translated in Polish, Russian, and Portuguese. Fellow of the International Tax Center Leiden and of the IBFD International Tax Academy in Amsterdam, he is the chairman of the Advisory Board of the IBFD and a member of the Young IFA Network Central Committee. He has lectured on international tax matters in several countries, including Brazil, Denmark, Kazakhstan, France, India, Italy, Latvia, Mexico, the Netherlands, Peru, Poland, Slovenia, Spain, Switzerland, Trinidad and Tobago, United Arab Emirates, the United Kingdom, the United States, and Venezuela. Principles of International Tax Planning, p. 36
Sandler, Daniel
Partner of Couzin Taylor LLP, Toronto, professor at the faculty of law, The University of Western Ontario, London, and senior research fellow at the Taxation Law and Policy Research Institute, Monash University, Australia. Daniels practice at Couzin Taylor focuses primarily on tax litigation, representing clients in disputes with the Canada Revenue Agency and the Ontario Ministry of Finance and before the courts. Prior to joining Western Law in 1995, Daniel was a member of the faculty of law, University of Cambridge and a research fellow for the Institute for Fiscal Studies and the Chartered Institute of Taxation. He has served as a consultant to the OECD, the Auditor-General of Canada, the Technical Committee on Business Taxation (Canada), the Department of Industry, Tourism, and Resources (Australia), and the Louisiana Department of Economic Development. Daniel has written several books and numerous articles and has spoken worldwide on various aspects of tax law and policy. Taxation of Entertainers and Athletes, p. 35
Rohatgi, Roy
Born in 1939, Roy is an economics graduate from London University and a UK/Indian chartered accountant. In 1994, Roy retired as a partner in Arthur Andersen after nearly 25 years with the firm. During this period, he worked in Europe, the Middle East and India. In the eighties, he spent everal years in India where he s e b sta lished and ran the Indian firm of Arthur Andersen as managing partner. Roy was a v isiting professor in international taxation for the Masters of Law program at the St. Thomas University School of Law, in Miami, Florida from 2002-2007. Since 1995, he has been the conference director of the International Taxation Conference, which he now organizes in Mumbai (India) each year in December under the Foundation for International Tax. The se ond edition of his book Basic Internac tional Taxation was published in the United Kingdom and India. It has also been translated into Chinese (2004) and Spanish (2007). Indian Tax Law, p. 30
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Sasseville, Jacques
Head of the Tax Treaty Unit of the Fiscal Affairs Division at the OECD. He holds university degrees in law and accounting (including masters degrees in both law and taxation). He has been with the OECD since 1995, and also from 1990 to 1993, when he was principal administrator and subsequently deputy head of the Fiscal Affairs Division. He has also worked with the Federal Government of Canada as counsel in the Tax Counsel Division (Department of Justice) and as head of tax treaties (Department of Finance). Previous work experience includes five years as professor in the Department of Accounting Sciences at the University of Quebec at Montreal, researcher and lecturer at the law faculty of the University of Montreal, and work as a tax lawyer in a Canadian law firm. He has written and lectured extensively on Canadian and international tax issues and is currently a member of the Permanent S cientific Committee of IFA. The Negotiation of Tax Treaties, p. 35
Schoueri, Lus Eduardo

Born in So Paulo in 1965. He holds the chair of tax law in the Department of Economic and Financial Law at the Law School of the So Paulo University; he is also professor at ackenzie M University, in So Paulo. He obtained his masters degree in law (legum magister) in 1992 at the University of Munich under the guidance of Professor Klaus Vogel. He achieved his doctors degree (1993) and the free p rofessors degree (1996) at the Law School of the Universidade de So Paulo. He is a partner of Lacaz Martins, Halembeck, Pereira Neto, Gu evich & Schoueri dvogados, vice r A p resident of the Brazilian Tax Law Institute (Instituto Brasileiro de Direito Tributrio IBDT) and vice president of the chamber of commerce of So Paulo ( ssociao C mercial A o de So Paulo ACSP). Tax Planning in South America, p. 38
Schuch, Josef
Josef holds a master of laws and an MBA degree. He received his doctorate in law in 1998 for a work on expenses and losses under tax treaty law and his PhD in 2002 for a work on timing issues under tax treaty law. His research and publishing activities mainly focus on international tax law. Since 2002, he is a professor of international tax law at the WU. Josef is a partner of Deloitte Austria. Tax Policies in the EU, p. 42 Tax Treaties Tax Planning Tools and Specific Interpretation Issues, p. 39
Seer, Roman
Born in Detmold/Germany in 1960. In 19791989 gained tax practice experience as a tax officer in the German tax administration and later as a tax consultant assistant. From 1990-1996 was assistant professor at the Tax Law Institute of Cologne. After receiving his postdoctoral lecturing qualification (dissertation, 1992 and habilitation, 1996) he became professor and head of the tax law chair of the Ruhr-University of Bochum (RUB). Since 1994, he is a member of the Permanent Scientific Committee of the German Tax Law Association (GTLA). Since 2006, he is the chairman of the GTLA and member of the Academic Committee of the EATLP. Prof. Seer is editor of the scientific journal IWB (Internationale Wirtschaftsbriefe). His scientific focus is on the correlation of tax law and tax procedure in a national and international context. In 2009 he founded the Institute of Tax Law and Tax Procedure of the RUB. Exchange of Information, p. 48
Schn, Wolfgang
Born in 1961, he studied law and economics at Bonn University. His dissertation on partnership taxation was finished in 1985. After receiving his postdoctoral lecturing qualification in 1992, he became professor of civil, company and tax Law at the University of Bielefeld in the same year, as well as director of the Department for German, European and International Economic Law. From 1996 2002, Professor Schn was director of the Department for Tax Law and the Center for European Economic Law at the University of Bonn. In 2002, he was appointed director at the Max Planck Institute for Intellectual Property, Competition and Tax Law (Department of Accounting and Taxation) in Munich and professor at Munich University. He is member of the Scientific Advisory Board to the German Federal Ministry of Finance, member of the board of the German Lawyers Association and member of the Board of Trustees of the IBFD. He is co-editor of the Zeitschrift fr das gesamte Handels- und Wirtschaftsrecht, the oldest German-language journal on commercial and company law and of the journal IStR (Internationales Steuerrecht). Trends in EU Tax Law, p. 45
Schima, Bernhard
Born in Vienna in 1968, where he also obtained his law degrees (masters degree in 1991, doctorate in 1994). After completing postgraduate studies at Harvard Law School (LLM in 1994), he joined the Department for Legal Affairs in European Integration in the Constitutional Law Section of the Austrian Federal Chancellery. From 1995 to 2003 he was a member of the chambers of Judge Dr. Peter Jann at the European Court of Justice. In 2003, he joined the European Commissions Legal Service. In 2004, he obtained the postdoctoral qualification to lecture in European law at the University of Graz. He has taught and published extensively on various matters of European Union law. The EU: Legal and Institutional Framework, p. 42
Simader, Karin
Born in Linz in 1984. Ms. Simader studied international business and business law at the WU and at the University of Texas at Austin. For two years, she worked at Deloitte in Vienna. Currently, she is a research associate and a lecturer at the
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Institute for Austrian and International Tax Law at the WU. Her main research areas are European and international tax law. She has already published more than 15 articles in tax journals and book contributions. Ms. Simader is currently enrolled in the PhD program in social and economic sciences at the WU. Her PhD thesis is entitled Withholding Taxes and the Fundamental Freedoms. Limits to Tax Planning Seminar II and III, p. 50
cial and tax accounting. He is a member of the Scientific Council of the Federal Ministry of Finance, visiting professor at Center for European Economic Research (ZEW), international research fellow at Oxford University, Sad Business School, academic director of the Executive Master of Accounting & Taxation, Mannheim Business School, and has been appointed as a member of the expert group on company taxation by the European Commission. Tax Policy and Planning in Europe, p. 45
Storck, Alfred
Studied economics, focusing on accounting, auditing, company taxation, and international tax law at the niversity U of Mannheim/Germany (Prof. Dr. Dr. Otto H.Jacobs). Serving for five years as associate professor at that university, he completed his PhD in the international tax law and econo ics m in 1979. In 1980, he became a qualified German tax consultant. After serving as research assistant at the Institute for Empirical Studies at the University of Mannheim/Germany, Alfred Storck joined 1981 a multinational company as international tax counsel. In 1986 Alfred Storck was appointed as group tax officer of the Swiss-based BBC Group and in connection with the global merger of BBC and Asea became 1988 the group tax officer of the newly formed ABB Group, headquartered in Zurich/Switzerland. From 2003 till March 2009, he served as deputy CFO of ABB Ltd and continued to head the Group Functions Finance and Taxes. Alfred Storck is a member of the Tax Committee of the Business and Industry Advisory Council (BIAC) at OECD and the Tax Group of BUSINESSEUROPE. Since April 2009, Alfred Storck is visiting professor at the Institute for Austrian and International Tax Law (Prof. Dr. Dr.h.c. Michael Lang) at the WU. Alfred Storck is also honorary professor for company taxation and managerial finance at the Institute of Accounting, Controlling and Auditing (ACA), at the University of St. Gallen/ Switzerland. International Group Financing, p. 49 Tax Planning in Multinational Companies, p. 38
Smiley, Stafford
Born in 1948, Mr. Smiley graduated from Harvard Law School in 1976 and served as clerk to Judge Arnold Raum of the United States Tax Court from 1976 to 1978. He joined the law firm of Caplin & D rysdale, Chartered, in Washington, DC, in 1978, became a member of the firm in 1982, and practiced at the firm as a full-time tax adviser until August 2008. He remains ofcounsel to Caplin and Drysdale, where he continues to specialize in US international tax matters. Mr. Smiley has taught in the graduate tax programs of George Washington University and the Georgetown Law Center, at the New York University Institute of Taxation, and at universities in Poland, Russia and elsewhere in Europe and Asia. In September 2008, he joined the faculty of the Graduate Tax Program of Georgetown Law Center on a full-time basis. He currently serves as international tax editor for the US legal journal Corporate Taxation. Tax Planning in the US, including Transfer Pricing, p. 39
Staringer, Claus
Claus Staringer was born in Vienna in 1967. He received his legal education at the University of Vienna as well as at the WU. Claus Staringer is the author of a number of articles and publications. He is a professor for tax law at the WU. Since 1997, he is admitted as tax adviser. He is a principal consultant with the law firm Freshfields Bruckhaus Deringer in Vienna Dual Residence, p. 32
Steines, John P. Jr.

Has been professor of law at New York University School of Law for over 30 years, where he has taught a wide variety of courses in the LLM program in taxation. A former editor-in-chief of the Tax Law Review, he is a frequent expert witness in tax controversies and speaker to professional groups and is the author of numerous articles on partnership, corporate, and international tax issues as well as a book for students and practitioners on international aspects of US income taxation. Mr. Steines is counsel to the law firm of Cooley LLP, where he has a broad-based practice in partnership, corporate, and international tax matters. Formerly, Mr. Steines was counsel to the law firm of Weil, Gotshal & Manges and the accounting firm of Deloitte & Touche. US Tax Law, p. 31
Strzlinger, Birgit
Born in Wels in 1982. She completed her studies in international business administration at the University of Vienna. In 2006, she became research associate at the Institute for Austrian and International Tax Law at the WU and has lectured there since 2008. In her research she focuses particularly on international tax law and accounting tax law. International Group Financing Seminar II and III, p. 49
Spengel, Christoph
Born 1964 in Heidelberg, is a professor of international taxation at the University of Mannheim. His main research interests are in the areas of international taxation (tax planning, comparison of company tax burdens), company taxation in the European Union (tax harmonization, group taxation, profit allocation), and finan-
23
Sutter, Franz Philipp

In 1998, graduated summa cum laude from the law faculty of the Vienna University and joined the Department of Austrian and International Tax Law of the WU as assistant professor; from 2001 to 2002, member of the legal service of the Federal Chancellery (Bundeskanzleramt-Verfassungsdienst) responsible for the representation of the republic of Austria in written procedures before the Austrian Constitutional Court and the European Court of Justice in tax matters; before the ECJ also pleading appearance in the oral procedure; in 2003 received a scholarship of the Austrian Academy of Science for his doctoral thesis on EC state aid law and taxation that earned several international scientific awards after its publication in 2005. Since 2004, adjunct university lecturer in Vienna and since March 2001 Austrian correspondent of European Taxation. In 2006 joined the Austrian Federal Ministry of Finance; since 2008, deputy head of the Tax Policy Department, responsible among other things for constitutional and European law issues and procedures; since 2010, deputy head of staff of the State S ecretary of Finance. EU State Aid Rules and Taxation, p. 41
Titz, Elisabeth
Born in Oberpullendorf in 1985. Ms. Titz studied economics and law at the WU. She worked at Deloitte in Vienna for an internship. Currently, she is a research associate and a lecturer at the Institute for Austrian and International Tax Law at the WU. Her main research areas are corporate and business taxation. She has already published more than 15 articles in tax journals and book contributions. Ms. Titz is currently enrolled in the PhD program in social and economic sciences at the WU. Limits to Tax Planning Seminar II and III, p. 50
Thmmes, Otmar
Serves as Global Managing Partner of Strategic Clients at Deloitte Touche Tohmatsu. The main focus of his role is on generating highquality service to clients the world over. As such, his responsibilities cut across all Deloitte member firms. They apply to supporting innovation, strengthening industry practices, and identifying leadership and crossborder management strategies. He began his career at Deloitte at the German member firm more than 25 years ago. Since then, he has held national and global positions, including a twoyear assignment at the European Commission in Brussels. An authority on international tax law, he has served as a global lead tax partner for a number of major clients, such as Daimler, Deutsche Bank, and Siemens. A doctor of jurisprudence and honorary university professor, he speaks frequently at educational institutions and leading international client conferences on a range of topics. International Mergers and Acquisitions, p. 36
van Thiel, Servaas

Born in the Netherlands in 1956. Present functions include the following: (I) Academic: Professor in international and European taxation at the Free University Brussels (since 1987); faculty member of Europese Fiscale Studies at Erasmus University Rotterdam (since 1993); director of the Brussels LLM Program and member of the Executive Board of the Brussels Institute for European Studies (since 2003); (II) Professional: Staff member of the European Union (since 1988), first with the European Court of Justice and subsequently with the EU Council of Ministers; (III) Other: Part time judge in the Regional Court of Appeals of Den Bosch, Netherlands (since 2003); member of the ECJ Tax Force of the CFE (since 2009). In the past Prof. van Thiel was, among other things, adjunct professor of law at New York University (2009-2010), senior researcher at the IBFD (1983-1987), ad hoc consultant to the UN Economic Commission for Africa (1985), the UN Centre for Transnational Corporations (1987) and the IBFD task force on China (2004), and editor of the International VAT Monitor (1991-1992). WTO and Tax Policy, p. 46
Toifl, Gerald
Born in Wels in 1969 and completed his stu ies in d law at the University of Vienna in 1994. In that year he also joined the Department of Austrian and International Tax Law at the WU. In 1997, Gerald started at the IBFD International Tax Academy, moving on to Loyens & Volkmaars (Amsterdam) in 1999 and to Wolf Theiss (Vienna) in 2000. Since 2002, he has been tax adviser and partner with Leitner + Leitner (Vienna/Salzburg). In 2003, he was admitted to the Austrian bar as attorney-atlaw and he received his doctoral degree at the University of Vienna. Since 2009, Gerald has been professor of tax law at the University Salzburg. Tax Treaties Tax Planning Tools and Specific Interpretation Issues, p. 39
Terra, Ben
Ben Terra (1947) studied international law at the University of Amsterdam and (indirect) taxation at the University of Leiden. He wrote a thesis on VAT on cross-border transactions. Ben was head of the postgraduate training in VAT, customs and excises at the Ministry of Finance in The Hague, professor of law at the University of Leiden and visiting professor at the Universities of Florida in Gainesville, of Sydney in Australia, the Gmimo University in Moscow and the Anton the Kam University in Surinam. Until 2003, he was head of the E&Y global indirect tax practice. In 2007, he became doctor economiae honoris causa at the University of Lund in Sweden. At present, he is professor of law at the Universities of Amsterdam, the Netherlands and Lund, Sweden. EU and Indirect Taxation, p. 40
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Tchler, Nicole
Born in Vienna in 1981, she obtained a business degree from the WU in 2006. After being employed by a tax consultancy firm in Vienna, she became research and teaching associate at the nstitute for I A ustrian and International Tax Law at the WU in 2008. Ms. Tchler has published a n umber of articles and lectured on umerous n o ccasions on national and international tax law. Exchange of Information Seminar II and III, p. 48
Amsterdam Center for International Law (ACIL) of the UvA. He is affiliated to Loyens & Loeff as of-counsel, where he is head of the European direct tax law team. Weber is a deputy judge at the Den Bosch Court of Appeal, where he is primarily involved in cases related to European tax law. He published several academic publications and one is the book Tax avoidance and the EC treaty freedoms (2005). Abuse Concepts in European Tax Law, p. 42
Zimmer, Frederik
Born in 1944. He has his law degree and his doctors degree from the University of Oslo (achieved in 1970 and 1978, respectively). He has been professor of tax law there since 1987 and dean of the faculty of law from 1995 to 2000. Professor Zimmer has chaired governmental commissions investigating aspects of VAT, real estate tax and inheritance tax, and he has also been chairman of the claims board for taxation of large companies in Norway (1993-2005). He has been chairman of the IFA Norwegian branch, and has been a member of the Permanent Scientific Committee of IFA and Chairman of the Nordic Tax Research Council. He acted as judge in the Norwegian Supreme Court for three periods, in 2002, 2003 and 2007. Tax Law of the Nordic Countries, p. 31
Wiman, Bertil
He wrote his doctoral thesis on transfer pricing and has since then concentrated on international, EC and corporate taxation. He holds an LLM in taxation from the University of Minnesota. He is currently professor of fiscal law at Uppsala University, Sweden, and director of Uppsala Centre for Tax Law. Wiman has been visiting scholar at the Universities of Munich and Minnesota, and visiting professor at Georgetown University (Washington DC), University of Florida and the WU. In addition, he has lectured at many other Swedish and foreign universities, i ncluding Austria, Belgium France, Germany, the Ne herlands, the Nordic countries, and t the United States. He is the chairman of the Swedish IFA branch and a member of the board of the EATLP. Tax Law of the Nordic Countries, p. 31
Waldburger, Robert
Robert Waldburger graduated from the University of St. Gallen, Switzerland in 1979 with a degree in economics and complemented his studies with a degree in law in 1984 from the same university. He started his professional career in 1984 as a member of the Department for International Fiscal Law and Double Taxation Agreements at the Swiss Federal Tax Administration in Berne. From 1987 to 1989, he was an expert for international law within the Revisuisse Group, before joining Arthur Andersen in 1990 as regional office head and partner. Parallel to his professional career, Robert Waldburger obtained his PhD in law in 1990 and became professor of fiscal law at the University of St. Gallen in 1994. At the same time, he was appointed director of the Institute of Public Finance and Fiscal Law of the University of St. Gallen. From 1998 to 2007, Professor Waldburger was the delegate for international tax treaties and head of the Department of International Fiscal Law and Double Taxation Agreements at the Swiss Federal Tax Administration. Swiss Tax Law, p. 31
Zolt, Eric
BS in Econ (Wharton School, University of Pennsylvania), MBA and JD (University of Chicago). Eric Zolt is the Michael H. Schill professor at the UCLA School of Law. He specializes in individual and corporate tax law. His recent scholarship has focused on taxation in developing countries. Professor Zolt has served as a c onsultant on tax policy matters to the International Mo etary Fund, the World Bank, and n the US Treasury Department. Before coming to UCLA, he was a partner in the Chicago law firm of Kirkland & Ellis. He founded and served as the first director of the US Treasurys Tax Advisory Program in Eastern Europe and the Former Soviet Union. Professor Zolt also served as the director of the International Tax Program at Harvard Law School. He is a cofounder and member of the Executive Committee of the African Tax Institute, a raining t and research institute for government tax officials in Africa. US Tax Law, p. 31
Zatschler, Carsten
Born 1974 in Brussels (Belgium). Studied law at the universities of Cambridge (B.A., M.A.), Paris II (Matrise) and Berlin (LLM). Called to the Bar of England and Wales in 1999, practised as a barrister in London specializing in public and commercial law. Since 2004, legal secretary (Rfrendaire) to Sir Konrad Schiemann, Judge at the Court of Justice of the European Union. Particular interest in the economic policy aspects of EU law, notably tax, free movement, state aids and competition. Regularly teaches various aspects of EU law on postgraduate courses run by Kings College London, the University of Cambridge, and the Saarland University. ECJ Case Law, p. 40
Weber, Dennis
Dennis Weber (1970) is a professor of european corporate tax law at the University of Amsterdam (UvA). He is in charge of the international and European tax legislation research that has been accommodated at the
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When you add it all up, it gures. PwC.

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Course schedule
The University Act provides for a total of 90 ECTS for the LL.M. degree course. The program is divided into several blocks of lectures and comprises the following subjects:
ECTS
Principles of selected tax systems (p. 29) ............................................
18 18 18 8 6 4 6
Tax treaty law (p. 32) ............................................................................................. International tax planning (p. 36) ................................................................
Tax law of the EU (p. 40) .........................................................................................
Anti-avoidance measures (p. 42) ...................................................................... International tax policy (p. 44) ........................................................................... Supplementary courses (p. 46) .......................................................................... Master thesis (p. 48) .....................................................................
12
Total ..................................................................................................................................
90
The program put my tax k nowledge in a new perspective. Igor Loncarevic, Serbia, Full-time 04/05 KPMG, Belgrade
27
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Course contents
The courses of the 2011/2012 and the 2012/2013 full-time programs, and the 2011/2013 part-time program are described in detail below. The figures in brackets after the title indicate the credits per course. Each description also states the program in which the course is offered.
Description
2011/2012 full-time program 2012/2013 full-time program 2011/2013 part-time program
Abbreviation
F 11/12 F 12/13 P 11/13
Australian Tax Law (3)

Barkoczy, Stephen, F 12/13, P 11/13 This course provides a broad overview of Australian taxation law. It discusses the history and constitutional framework that lies behind Australias tax rules and outlines key aspects of the Australian tax administrative system. The course examines Australias tax rules from both a legal and policy perspective. It focuses on Australias three most important Commonwealth taxes: goods and services tax, income tax and fringe benefits tax. Special attention is paid to the tax treatment of individuals, companies, partnerships and trusts. The course also examines a number of Australias special tax expenditure programs, including its superannuation system and venture capital incentives. Key aspects of Australias international tax rules are also examined in the course.
Principles of selected tax systems (18)
F 12/13: April 19-20, 2013 P 11/13: April 19-20, 2013
Austrian Tax Law (3)

Aigner, Dietmar, F 11/12 Ehrke-Rabel, Tina, F 12/13, P 11/13 This course provides students unfamiliar with the Austrian tax system with a foundation in Austrian domestic tax law, including personal taxation, corporate taxation, the rudiments of partnership taxation and indirect taxation (including VAT). The course also discusses the domestic taxation of inbound and outbound investments and gives students an opportunity to compare their own countrys system with that of Austria.
F 11/12: September 30 October 1, 2011 F 12/13: November 16-17, 2012 P 11/13: November 16-17, 2012
Belgian Tax Law (1.5)

Malherbe, Jacques, F 11/12 This lecture introduces individual and c orporate taxation under Belgian law. Furthermore, attention is also given to mergers and group taxation, taxation of foreign income to domestic recipients (business income, dividends, interest, capital gains) and taxation of domestic income to foreign recipients (withholding taxes and exemptions, permanent establishments, non-discrimination). Special issues, such as the taxation of foreign entities and domestic entities subject to a special tax system (finance companies, investment funds), are addressed as well. Procedural issues, reporting and the exchange of information are also covered.
F 11/12: November 11, 2011
29
Course contents
Comparative Tax Law (3)
Brooks, Neil, F 11/12, P 11/13 Michielse, Geerten, F 12/13 While the underlying foundations of most modern tax systems are similar, each tax law in the West has its own distinct features resulting from different tax policy choices. This course reviews the key tax policy issues considered by tax legislators and considers how tax policy choices impact on tax law design. Within each kind of tax law, different tax treatments may apply to economically similar transactions that have a different legal character. The course is built up around the concepts used by legislators and touches upon issues such as constitutionality, anti-abuse, the concept of income, relationship with accounting rules, etc.
F 11/12: November 4-5, 2011 F 12/13: October 5-6, 2012 P 11/13: November 4-5, 2011
French Tax Law (1.5)

Gutmann, Daniel, F 12/13, P 11/13 This lecture introduces individual and corporate taxation under French domestic tax laws. Special issues such as the taxation of foreign and domestic entities subject to special tax regulations are addressed. Furthermore, this lecture covers mergers and taxation of groups, international taxation, the taxation of foreign income to domestic recipients and the taxation of domestic income to foreign recipients, as well as procedural issues, procedure reporting and the exchange of information.
F 12/13: May 18, 2013 P 11/13: May 18, 2013
German Tax Law (1.5)

Jochum, Heike, F 11/12, P 11/13 Rust, Alexander, F 12/13 The principle of the ability to pay is significant for the legal doctrine and the structure of German tax law. Taking this as a starting point, the course aims to provide the necessary understanding for a systematic approach to the legal field of German tax law in general. It discusses basic issues such as the scope of income tax law and corporate tax law, the assessment of taxable income, deductions and refunds, special approaches in taxing labor income as well as capital income and the most important rules and instruments of general tax law. On the one hand, the lecture is intended to create a basis for various, more specific lectures, and, on the other, to develop an understanding of the interrelations between tax law and constitutional law as well as European law.
F 11/12: May 4, 2012 F 12/13: November 9, 2012 P 11/13: May 4, 2012
Indian Tax Law (3)

Ostwal, T.P. / Rohatgi, Roy, F 11/12 India is developing fast as a major international center for cross-border trade and investment. As a country that favors source-based taxation, it largely follows the United Nations Model in its treaties. Moreover, its domestic tax law and practice often promote its national economic and social policies and are not determined by just fiscal considerations. This lecture will provide a broad understanding of the current Indian tax system. In particular, the lecture will cover the international tax framework (both law and practice) under domestic law and the role and interpretation of tax treaties based on various administrative and judicial decisions in India and rulings given by its Authority for Advance Rulings.
F 11/12: April 27-28, 2012
30
Course contents
Swiss Tax Law (1.5)
Waldburger, Robert, F 12/13, P 11/13 This course begins with a look at the Swiss tax system, which is characterized by various peculiarities due to the federal structure of the state. It then illustrates the most important legislative principles and their application resulting from the federal constitution and existing legal protection mechanisms. This course deals with the most important tax forms, with international aspects always to the fore. Then, a comprehensive illustration of the tax implications of important economic issues is provided, such as the taxation of the transfer of assets, provision for asset accumulation and the taxation of enterprises. This is followed by a description of the consequences of Swiss double taxation agreements, including the Swiss provisions for implementation, and the principles of international administrative and legal assistance applied in Switzerland.
F 12/13: May 17, 2013 P 11/13: May 17, 2013
Tax Law of the Netherlands (1.5)

Essers, Peter, F 11/12, P 11/13 This lecture deals with the national and international tax system of the Netherlands by examining general characteristics, the taxation of profits, capital income and capital gains, fiscal consolidation, mergers and de-mergers, participation exemption, abuse of the law, partnerships, ruling practice and tax treaty policy.
F 11/12: May 5, 2012 P 11/13: May 5, 2012
Tax Law of the Nordic Countries (1.5)

Wiman, Bertil, F 12/13 Zimmer, Frederik, F 11/12 The Nordic countries have much in common as far as legal culture and legal structure are concerned, even though only three of the five countries are members of the EU. However, there are also significant differences, not least within the field of tax law. This lecture provides a general overview of the Nordic tax systems by focusing on issues of special interest to students from non-Nordic countries. Attention is given to three main areas: first, issues of general theoretical interest, such as dual income tax; second, essential rules of particular importance for foreign investors and Nordic domestic companies investing abroad; and third, international tax issues which deal with the Nordic multilateral tax treaty, together with the main principles of international tax law in each state.
F 11/12: November 12, 2011 F 12/13: November 10, 2012
US Tax Law (3)

Steines, John, F 11/12, P 11/13 Zolt, Eric, F 12/13 This lecture introduces and explains the tax law of the United States of America, with emphasis on the US Federal income tax and international income tax systems. Brief attention will also be given to state and local (sub-national) taxes. Income tax regimes for individuals and various forms of business associations (corporations, partnerships, limited liability companies, electing S-Corporations, proprietorships and hybrids) are presented. Regarding US international income taxation, attention is mainly paid to US statutory law, both as applicable to inbound and outbound foreign investment. Tax planning, tax policy, tax reform proposals, and recent legislative and judicial developments also form part of the program.
F 11/12: December 16-17, 2011 F 12/13: December 7-8, 2012 P 11/13: December 16-17, 2011
31
Course contents
Tax treaty law (18)
Australian Tax Treaty Policy (1.5)
Pickering, Ariane, F 12/13 Australias tax treaties reflect its position in the global economy as both a significant importer of, and a significant exporter of, capital and technology. Accordingly, Australias tax treaties include aspects of both the OECD Model Tax Convention and the UN Model. This lecture explores how Australian treaties achieve a balance between source and residence taxing rights, for example, through variations to the OECD Model definitions of permanent establishment and immovable property, and in the distribution of taxing rights over passive income and capital gains. It also looks at some of the unique features of Australian tax treaties which are designed to address possible uncertainties in the existing model treaties, such as the taxation of business profits derived through trusts. Finally, the lecture examines how Australias tax treaty policy has evolved in response to a changing economic environment.
F 12/13: May 25, 2013
Conflict Settlement in Tax Treaty Law (1.5)

Dunahoo, Carol, F 11/12, P 11/13 Although tax treaties generally seek to avoid cross-border disputes by providing a series of rules to allocate tax revenues between the contracting states, the number and magnitude of such disputes continue to grow. This lecture provides general background regarding the nature of current tax treaty disputes and the practical difficulties encountered in their resolution. It considers the tools currently available for the resolution of such disputes under bilateral tax treaties and other agreements, including the mutual agreement procedure conducted by the competent authorities, advance pricing agreements under bilateral treaties, and the EU multilateral convention on arbitration. The lecture also discusses recent OECD initiatives to improve dispute resolution and to promote the broader adoption of mandatory, binding arbitration.
F 11/12: May 19, 2012 P 11/13: May 19, 2012
Dual Residence (1.5)

Staringer, Claus, F 11/12, P 11/13 Taxpayers operate internationally and globally to an ever-increasing extent. Therefore, dual (or multiple) residence in more than one tax jurisdiction is an obvious issue of international tax law. This lecture analyzes the concept of residence in domestic and treaty tax law, including the tie breaker-mechanisms applied in dual residence situations. Specifically, the lecture discusses suitable options for establishing companies that are resident for tax purposes in more than one country and their applicability within the framework of international tax planning. The law on double taxation agreements plays a pivotal role in this matter. Interesting aspects to be considered in the overall design result from the interplay between tax treaties and national law. Questions arising due to the establishment of dual resident companies for tax purposes, particularly related to possible triangular cases regarding tax treaties, are discussed by looking at practical case studies.
F 11/12: June 15, 2012 P 11/13: June 15, 2012
32
Course contents
Permanent Establishments in International Tax Law (1.5)
Garca Prats, F. Alfredo, F 12/13 This course analyzes the concept of and the different types of permanent establishments, the importance of permanent establishments in trans-national businesses, and the functions of the PE clauses in domestic tax law and double tax treaties. Special attention will be given to construction projects, auxiliary activities, agents and sales representatives and to supply chain structures. The attribution of profits to permanent establishments will also be dealt with, with special reference to and analysis of the OECD Guidelines in this regard. Attention will be paid to the influence of EC law for the taxation of permanent establishments in international tax law.
F 12/13: February 23, 2013
Principles of Tax Treaty Law (3)

Lang, Michael, F 11/12, F 12/13, P 11/13 The treaty models of the OECD serve as the basis for most existing tax treaties worldwide. Taking them as a starting point, the lecture aims to provide the necessary understanding for a systematic approach to the legal field of tax treaties in general. It discusses basic issues such as the scope of tax treaties, their distributive rules and the methods available to eliminate double taxation, as well as other important treaty rules, including the prohibition of discrimination, the mutual agreement procedure and the exchange of information. On the one hand, the lecture is intended to create a basis for various, more specific lectures, and, on the other, to develop an understanding of the interrelations between individual treaty rules that are also dealt with in other lectures.
F 11/12: September 22-23, 2011 F 12/13: September 13-14, 2012 P 11/13: September 22-23, 2011
South American Tax Treaty Policy (1.5)

Kana, Liselott, F 12/13, P 11/13 The course provides a short introduction to doing business in general in South America, touching on the Agreements for the Protection of Foreign Investment, looking at the background to free trade initiatives in the Americas and the structure of the basis for negotiation, in order to understand which possible investment and commercial issues may arise in the area in the future. The tax aspects of the investment and free trade agreements are covered. Some specific countries and their tax policies in relation to foreign investment are introduced in more depth. The trend towards tax treaties in the region is analyzed, especially the Andean Pact and the OECD Model as applied by South American countries. Some specific differences and special issues in tax treaties in the region are presented and discussed.
F 12/13: January 18, 2013 P 11/13: January 18, 2013
33
Course contents
Tax Treaties between Developed and Less Developed Countries (1.5)
Gustafson, Charles, F 12/13, P 11/13 Bilateral tax treaties between industrialized countries arise in a context where the flow of investment and trade creates issues common to the tax policies of both treaty countries. Treaties between industrialized and developing countries, however, are negotiated in a sometimes dramatically different context because of the disparity in the flow of investment and trade and, therefore, income potentially subject to income taxation. This lecture will focus on the way in which such differences are reflected in model treaties developed by international organizations and the substance of treaties that have been concluded between industrialized and developing countries. Issues discussed will include the measure of corporate profits, defenses to transfer pricing abuses, withholding taxes on investment income and the taxation of compensation. Issues of administrative cooperation, including information exchange and the arbitration of tax issues between treaty countries, will also be examined.
F 12/13: March 8, 2013 P 11/13: March 8, 2013
Tax Treaty Developments: Source versus Residence Principle (1.5)

Kemmeren, Eric, F 12/13, P 11/13 Current tax treaty practice has been based on the residence principle for a long period. This practice is rooted in reports of the League of Nations published in the 1920s. A question that can be raised is whether the concepts of the 1920s are still valid nowadays. The lecture aims at a better understanding of flaws in double tax conventions because of the application of the principle of residence, and of opportunities which the application of the principle of source or the principle of origin offers to mitigate such flaws. The principle of residence offers opportunities for tax planning without really affecting the way income is produced. It may even cause tax treaty abuse. These phenomena trigger reactions by contracting states in order to protect source state tax jurisdiction under double tax conventions. Developments in these fields will be discussed not only from the perspective of legal and economic principles, but they will also be illustrated with practical examples of tax planning and counter-reactions in order to better understand the functioning and the disfunctioning of current double tax conventions. Furthermore, developments of EU law affecting double tax conventions will also be discussed. One development is that EU law reduces the dominant position of the principle of residence in favor of the source principle. Finally, alternative tax treaty systems based on the principle of source or origin will also be discussed.
F 12/13: March 22, 2013 P 11/13: March 22, 2013
Tax Treaty Interpretation (3)

Avery Jones, John F. / Baker, Philip, F 11/12 Tax treaties are international treaties which must be interpreted according to international rules, as laid down in the Vienna Convention on Treaties. Furthermore, tax treaties, which are drawn up in line with the OECD Model Double Taxation Convention, contain separate interpretation guidelines in Article 3 paragraph 2 of the Model Convention. Both the content of the Vienna Convention on the Law of Treaties and the special interpretation rules of Article 3 paragraph 2 of the OECD Model Double Taxation Convention leave some room for interpretation. The lecture covers these problems, as well as the importance and implications of the OECD Commentary on the interpretation of bilateral tax treaties.
F 11/12: October 21-22, 2011
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Course contents
Taxation of Entertainers and Athletes (3)
Sandler, David, F 11/12, F 12/13 Entertainers and athletes are among the most mobile individuals in the world. The nature of the income they earn is varied and, in some cases, substantial. The OECD Model Convention on Income and Capital has had a special provision dealing with entertainers and athletes since the original 1963 draft onvention. c This lecture introduces issues involved in the taxation of international entertainers and a thletes. With the help of case studies, this l ecture examines the characterization (for domestic law and tax treaty purposes) of income that entertainers and athletes earn, alternative regimes that can be used by c ountries to tax such income, the application of EU law to the taxation of such income, and the application of OECD Model provisions (and variations found in bilateral tax treaties).
F 11/12: November 25-26, 2011 F 12/13: April 26-27, 2013
The Negotiation of Tax Treaties (3)

Lthi, Daniel / Sasseville, Jacques, F 11/12, F 12/13, P 11/13 This course will allow students to examine the main policy and technical issues involved in the negotiation of tax treaties. It will first explore the main elements that determine a countrys tax treaty policies, including the relevant features of its domestic tax system and economic factors. It will then focus on the identification of the main issues involved during the negotiation of each article of a typical tax treaty. The course will also examine the various steps for the conclusion of a tax treaty and the process of negotiation, taking into account the role of model conventions and previously concluded treaties.
F 11/12: January 27-28, 2012 F 12/13: November 2-3, 2012 P 11/13: November 2-3, 2012
The Relevance of OECD Documents for the Interpretation of Bilateral Tax Treaties (1.5)
Reimer, Ekkehart, F 12/13, P 11/13 Since its foundation in 1948/1961 and the publication of its first Model Double Taxation Convention, the OECD has gained undisputed leadership, authority and expertise in the field of tax treaties. The course reflects on the early days of OECD and tries to mark the decisive steps in the evolution of what has now become a highly sophisticated network of rules and reports, customs and institutions on international taxation. The idea is that understanding the historical background of a rule and of its travaux prparatoires (cf. Art. 32 of the Vienna Convention on the Law of Treaties) is a valuable means of interpretation but that such understanding is also help ul for any future reformatting of tax f treaty law in Europe and worldwide. By role playing and the in-depth analysis of archive material, participants will learn to utilize OECD archive material, assess its historic relevance and connect it to up-to-date issues of tax treaty law.
F 12/13: October 19-20, 2012 P 11/13: October 19-20, 2012
Transfer Pricing (3)

Pijl, Hans, F 11/12, P 11/13 In international business, the determination of transfer prices is recognized as the greatest problem in the area of tax. Tax authorities worldwide are increasingly occupied with the verification of transfer prices. The course discusses the OECD Transfer Pricing Guidelines and the OECD Reports on the Attribution of Profits to Permanent Establishments. The practical implications of transfer pricing will be investigated with the help of case studies.
F 11/12: December 2-3, 2011 P 11/13: December 2-3, 2011
35
Course contents
International tax planning (18)
Financial Instruments in International Tax Planning (1.5)
Edgar, Timothy, F 11/12, P 11/13 This course reviews the basic policy and doctrinal principles relevant to the income tax treatment of financial instruments in a crossborder context. The course begins with a discussion of the general tax policy principles and financial market theories relevant to the income tax treatment of financial instruments. Students are introduced to the basic analytical concepts that are common to all financial instruments, including debt, equity and derivatives. After reviewing this introductory material, the course focuses on the income tax issues raised by the cross-border use of financial instruments. Topics covered include: (i) avoidance of non-resident withholding tax; (ii) thin capitalization; (iii) international tax arbitrage transactions; and (iv) application of tax treaties to derivative financial instruments.
F 11/12: May 18, 2012 P 11/13: May 18, 2012
Holding Companies and Tax Planning (3)

Kessler, Wolfgang, F 11/12 Maisto, Guglielmo, F 12/13, P 11/13 The use of holding companies has been gaining importance in international tax planning. Additional or reduced tax burdens can result from mezzanine holding structures, which also results in specific corporate tax difficulties. This course aims at describing the decisive structural and location factors. The management of intra-group income transfers, repatriation and allocation strategies, as well as viable combinations, are considered as options. Vital holding locations are described in more detail. Tax treaties are relevant for the use of holding companies, as they may not be eligible for advantages arising from such treaties.
F 11/12: June 8-9, 2012 F 12/13: June 13-14, 2013 P 11/13: June 13-14, 2013
International Mergers and Acquisitions (1.5)

Nakhai, Katja / Thmmes, Otmar, F 12/13, P 11/13 Globalization has largely increased the number of international mergers and acquisitions. This lecture aims at providing a comprehensive analysis of the tax aspects of such transactions both from the perspective of the seller and the purchaser. Presenters will discuss in detail the various stages of an acquisition process and address focus areas in a tax due diligence. They will also give an overview on typical focus areas of the tax structuring of an acquisition such as tax-efficient financing, holding company locations, transfer taxes as well as the tax treatment of transaction costs. Presenters will also give an in-depth overview of important tax aspects for the review of purchase agreements and financing/security documents supporting their analyses with practical examples. Presenters will make an effort to demonstrate to participants the interaction between the various work streams of an acquisition and explain how tax fits into the larger picture of the overall transaction.
F 12/13: May 3, 2013 P 11/13: May 3, 2013
Principles of International Tax Planning (1.5)

Russo, Raffaele, F 12/13, P 11/13 International tax planning has gained a lot of attention from both the perspective of taxpayers and tax authorities. This lecture deals with the building blocks of international taxation, such as the concept of permanent establishment and the arms length principle, as applied for international tax planning purposes. It focuses on the boundaries between legitimate tax planning, tax avoidance and tax evasion, by analyzing relevant case law. Finally, it deals with some tax planning schemes for multinational enterprises.
F 12/13: November 23, 2012 P 11/13: November 23, 2012
36
Course contents
Qualification Conflicts and International Tax Planning (1.5)
Brhler, Gernot / Heerdt, Tobias / Krenzin, Andreas, F 12/13 Qualification conflicts arise when two countries assess an international case in different ways. Here, it is first necessary to clarify how the double taxation convention deals with qualification conflicts. However, the lecture will focus on how qualification conflicts may thus be used to generate tax advantages within the framework of international tax planning. First of all, the basic procedure for the handling of qualification conflicts is developed. Subsequently, these considerations are applied to practical cases.
F 12/13: June 7, 2013
Tax Consequences of Mergers in Europe (1.5)

Hohenwarter-Mayr, Daniela, F 11/12 Globalization has greatly increased the number of international mergers and acquisitions. This lecture aims at providing a comprehensive analysis of the tax aspects of such transactions from the perspective of European law. On the basis of the EU Merger Directive and the case law of the European Court of Justice, topics such as the (cross-border) utilization of losses, taxation of hidden reserves, anti-abuse limitations and the relationship between the Merger Directive and the fundamental freedoms will be discussed.
F 11/12: March 10, 2012
Tax Planning in France (1.5)

Baconnier, Robert / Hellio, Francois, F 11/12 This lecture introduces individual and corporate taxation under French domestic tax laws. Special issues such as the taxation of foreign and domestic entities subject to special tax regulations are addressed. Furthermore, this lecture covers mergers and the taxation of groups, international taxation, the taxation of foreign income to domestic recipients and the taxation of domestic income to foreign recipients, as well as procedural issues, reporting and the exchange of information.
F 11/12: May 26, 2012
Tax Planning in Japan (3)

Masui, Yoshihiro, F 11/12 Names of Japanese companies are all too familiar. The business and tax environment in Japan, however, remains a mystery to many people living outside Japan. To bridge the gap, this course introduces the basic s tructure of Japanese taxation and examines some of the recent tax ontroversies c i nvolving international transactions.
F 11/12: March 2-3, 2012
Full-t
tud ime s
ent 0
7/08
37
Course contents
Tax Planning in Multinational Companies (3)
Storck, Alfred, F 12/13, P 11/13 Tax planning in multinational companies is seen from a corporate perspective as an integral part of business planning and depends in its scope and priorities on the business concepts and business models employed, the global footprint and value chain structures established, etc. as well as the tax management and tax risk approach chosen; it is also influenced by the companys legal structure and headquarters/ holding domicile (parent). The course addresses topics in the area of corporate tax policies/ tax risk management, governances in taxes, roles and responsibilities of tax functions, but mainly focuses on typical tax planning and tax risk management areas in multinational companies, such as (I) group legal structures, especially holding structures, (II) alternative transfer pricing methods and ways to avoid/minimize double taxation (APAs, MAPs, Arbitration), (III) design of charges/cost allocations schemes for management and administrative services, (IV) international group financings (capital markets/bank financings) and intra-group capital and lending structures (thin cap rules/interest charges), (V) design of license arrangements and cost-sharing arrangements for research and development and related intangibles (IPs), (VI) design of intra-group trademark ownerships and licensing arrangements, (VII) transfer pricing documentation.
F 12/13: March 1-2, 2013 P 11/13: March 1-2, 2013
Tax Planning in South America (1.5)

Schoueri, Lus Eduardo, F 12/13, P 11/13 Tax planning always requires extensive knowledge of a countrys tax system. International tax planning, moreover, also requires some knowledge of the tax systems of different countries, in order to enable the structuring of tax-efficient international arrangements. Considering this need, the lecture aims to provide an overview of the tax systems of the South American countries. The Brazilian case will be taken as the main example for discussions focused on value added and direct taxation, as well as tax treaty policy. Opportunities for tax planning on income taxation can arise from the adequate use of tax treaties between the Latin American and European countries, especially considering the massive presence of the matching credit mechanism in those treaties. Knowledge of the existence and the correct application of such mechanisms can be a valuable tool when deciding on investment and business structures involving South America.
F 12/13: January 19, 2013 P 11/13: January 19, 2013
Tax Planning in the Context of European Tax Directives (1.5)

Englisch, Joachim, F 11/12 Kofler, Georg, F 12/13, P 11/13 The European harmonization of Member States direct tax law has not seen much progress as yet. However, there are some European Directives dealing with significant cross-border aspects of company taxation: in particular, the ParentSubsidiary Directive, the Directive on Interest and Royalty Payments, and the Merger Directive. Taking them as a starting point, the lecture aims to provide the necessary understanding for a systematic approach to the legal field of ap lying harmonized European law in general. p Furthermore, it will discuss the basic concepts and rules of each Directive, such as their respective scope, their requirements for tax exemptions or tax deferrals, and the methods available to eliminate double taxation. A special focus will then be placed on the Directives manifold anti-abuse provisions and their relationship to the general anti-abuse doctrine developed by the European Court of Justice.
F 11/12: December 10, 2011 F 12/13: November 24, 2012 P 11/13: November 24, 2012
38
Course contents
Tax Planning in the United States, including Transfer Pricing (3)
Rosenbloom, David, F 11/12, P 11/13 Smiley, Stafford, F 12/13 The lecture will be a broad-based discussion of US cross-border tax issues, from both an inbound and outbound perspective. Planning considerations will be emphasized. The first day will concentrate on investments by foreign persons into the United States, and will include taxation at source on portfolio income, net income taxation, use of hybrid and reverse hybrid vehicles, and related treaty issues. Outbound issues will be discussed, but in more summary fashion. The second day will be devoted to transfer pricing.
F 11/12: March 16-17, 2012 F 12/13: December 14-15, 2012 P 11/13: March 16-17, 2012
Tax Treaties Tax Planning Tools and Specific Interpretation Issues (1.5)
Schuch, Josef / Toifl, Gerald, F 11/12, F 12/13, P 11/13 Tax treaties are very important tools in international tax planning. Parallel to the increase of cross-border transactions, more and more questions about the interpretation of specific tax treaty provisions are being raised. When attending this lecture, students will already have dealt with principles of tax treaty law and with many other issues of international tax law. With that knowledge in mind, they will deal with even more sophisticated issues of international tax law that play an important role in international tax planning.
F 11/12: June 22-23, 2012 F 12/13: June 21-22, 2013 P 11/13: June 22-23, 2012
VAT Planning (1.5)

Lejeune, Ine, F 11/12 Consumption taxes are a major source of tax revenues for governments worldwide and continue to grow as more territories move to more consumption-oriented tax regimes. By 2013, it is expected that 163 countries will implement a form of VAT/GST system. VAT and GST in the OECD countries increased from 1965 to 2003 twice, as a percentage of GDP, and this trend continues. There seems little doubt that VAT and GST are emerging as the taxes of the future, and the shift from direct to indirect taxation is a fast-developing reality. Consumption tax policies, legislation and auditing are all under increased scrutiny by governments and tax officials. Most businesses are reacting accordingly and are focusing on their indirect tax strategies, with particular emphasis on ensuring compliance and achieving efficiencies. The incorrect application of VAT can have severe and immediate cost implications for one or both parties involved in a transaction. Furthermore, harsh penalties are often levied by VAT authorities in the event of non-compliance. In order to effectively manage VAT opportunities and risks when trading in the EU a proper understanding of VAT rules in the EU is essential. The lecture focuses on providing the necessary understanding of international aspects of consumption taxation in general and the VAT system in particular. VAT planning possibilities and new developments in EU VAT policy will be discussed.
F 11/12: December 9, 2011
39
Course contents
Tax law of the EU (8)
ECJ Case Law (2)
Henze, Thomas / Zatschler, Carsten, F 11/12, F 12/13, P 11/13 Due to the unanimity requirement in the Treaty on the Functioning of the European Union (TFEU), the harmonization of the national rules on direct taxation is still in an undeveloped state. Nevertheless, the fundamental freedoms form a framework for national tax legislation with regard to intraUnion situations. The role of the European Court of Justice is not to replace the legislator but to provide an interpretation of the Treaty rules which, on the one hand, takes into account the particularities of national taxation and, on the other, ensures the effectiveness of the provisions of EU law. After a short introduction to the structure and functioning of the Court, the course focuses on the presentation and analysis of the recent case law (both judgments and Opinions of Advocates General) in the field of direct taxation. The aim is to explain the reasoning of the Court as well as to identify common lines in its decisions. In as far as the Court has already dealt with specific features of international taxation (e.g. CFC regulations, bilateral tax treaties), the lecture supplements other parts of the LL.M. Program.
F 11/12: October 28-29, 2011 F 12/13: September 28-29, 2012 P 11/13: September 28-29, 2012
EU and Indirect Taxation (1)

Terra, Ben, F 11/12, P 11/13 Harmonization of indirect taxes within the EU has already made significant progress. The legal framework of harmonization plays a pivotal part in this lecture, which aims to give students an overview of the status quo in VAT harmonization. Emphasis is placed on the basic principles of the common VAT system according to the Recast VAT Directive (as amended) and the Internal Market concept. This course also serves to give an overview of the legal decisions of the Court of Justice of the EU on VAT issues and illustrates the status quo of tax harmonization in the area of the indirect taxation of consumption.
EU and Third Countries (1)

Pistone, Pasquale, F 11/12, P 11/13 European tax law is no longer just a matter for the internal market, but also a source of rights with respect to relations with third countries. Starting from a comparison between the broad differences in two such scenarios, this teaching module will categorize third countries as a function of their type of relations with the European Union and its laws. Such a categorization will then be used to analyze selected tax issues, taking into account the relevant case law (European Court of Justice and those of national courts, including third countries), the applicable treaties (e.g. Economic and Partnership Agreements, Savings Agreements, bi- and multilateral tax conventions) and domestic tax rules. The focus of this teaching unit will be mainly on direct taxation.
40
Course contents
EU State Aid Rules and Taxation (1)
Eilmansberger, Thomas / Sutter, Franz Philipp, F 12/13 Although from the beginning the EU State aid prohibition of Art. 87 EC has been understood as a very broad ban on any form of subsidies, including tax benefits, cases in the field of taxes remained very rare up to the late 1980s. This reluctance to apply Art. 87 EC has, however, changed with the adoption of a Code of Conduct on Business Taxation by the EC Council, which encourages the Commission to commit itself to the strict application of the aid rules. On November 30, 1998, after this political backing, the Commission issued a communication concerning guidelines on the application of the State aid rules to measures relating to direct business taxation. Since then, several tax cases involving State aid have been brought before the EC Commission as well as before national courts and the Court of Justice. The law on avoiding double taxation in multilateral situations including both double tax conventions and unilateral double tax relief mechanisms has not been spared from this development and several concerns about State aid with regard to the details of current relief policy have been voiced recently. This course will therefore shed light on the status of the jurisprudence and prevailing opinion on substantive and procedural State aid law and will discuss the possible consequences for both domestic and international tax law issues.
F 12/13: October 13, 2012
Principles of European Tax Law (1)

Aujean, Michel, F 12/13 The institutional and decisional frameworks which surround the adoption of EU tax law are often considered to act as a constraint on the adoption of new tax proposals at EU level. The situation will be examined, having in mind the evolution in the last decades as well as the impact of the enlargement of the EU. The possibilities of using soft lax or the open method of coordination are frequently mentioned, and they will also be discussed in relation to the code of conduct on tax competition. The decisions of the ECJ have also been the subject of criticism by many Member States: is there an alternative to litigation? Is coordination of tax systems a way to make progress in a union with so many different tax structures? This gives rise to the particularly important question of whether the institutional structure applicable to taxation, which was established by the original Treaty of Rome in 1957, is still appropriate. Another question which will be addressed is whether and how, aside from generating public revenue, taxation could be used at the EU level to achieve the objectives of other policies.
F 12/13: October 12, 2012
Full
stu -time
dent
09/1
41
Course contents
Tax Policies in the EU (2)
Rdler, Albert / Schuch, Josef, F 11/12, F 12/13, P 11/13 This lecture is held in Brussels and presents future perspectives on European tax policy. Participants are given an insight into EU tax policy and its practical implications for the decision-making process through visits to the European Commission, the European Parliament and the permanent representatives of some Member States. Leading officials of the Commission and Member States and Members of the European Parliament will present and discuss their views on tax policies in the EU.
F 11/12: April 18-20, 2012 F 12/13: April 10-12, 2013 P 11/13: April 18-20, 2012
The EU: Legal and Institutional Framework (2)

Schima, Bernhard, F 11/12, F 12/13, P 11/13 Both European Union legislation and the case law of the European Court of Justice have an ever-increasing impact on tax law. To understand the mechanisms underlying this impact, knowledge of EU institutions and the sources of EU law is indispensable. These topics are therefore explored in detail in this course. The course places major emphasis on working with decisions of the European Court of Justice. On this basis, concepts of importance to tax law such as the direct effect and supremacy of EU law, Member State liability and issues of judicial protection are discussed.
F 11/12: October 7-8, 2011 F 12/13: September 21-22, 2012 P 11/13: October 7-8, 2011
Anti-avoidance Abuse Concepts in European Tax Law (2) measures (6) Weber, Dennis, F 12/13
Tax law contains many anti-abuse provisions. These provisions must be in accordance with Community law. Accordingly, further study of abuse concepts in European tax law is useful and desirable. This lecture will deal with the creation of and the content of the abuse
F 12/13: January 25-26, 2013
concepts in direct and indirect taxation in the EU. We shall discuss how the European Court of Justice treats abuse, the differences and similarities between the various abuse concepts, and if so to what extent, tax jurisdiction shopping is allowed.
This program can certainly not only change the course of your life but also lead you to new challenges. Krt Anna Maire Kelder, Estonia, Full-time 05/06 Alvin, Rdl & Partner, Tallinn
42
Course contents
Abuse of Tax Treaties (2)
Jirousek, Heinz / Loukota, Helmut, F 11/12, F 12/13, P 11/13 Double taxation conventions are an essential element in facilitating economic relations between states and encourage flows of capital and labor. In order to achieve this goal, the contracting states agree in these conventions on tax exemptions and on tax reductions. However, tax treaties are nowadays exploited at an increasing pace for other purposes without any sound business reason but with the sole aim of saving taxes. In this context aggressive tax planning has become a major concern for tax authorities around the world. This is the core topic of this course, which focuses on options for tax administrations to counteract such abusive practices and to protect their tax base against improper use of tax treaties. In-depth studies will be devoted to the relevance of specific or general anti-avoidance rules in treaties as well as to the importance of the beneficial ownership concept inherent in treaty provisions. In this framework the use of base companies and conduit companies and of various other tax planning vehicles will be thoroughly analyzed. Also, the technique of combating abusive transactions through the transfer pricing mechanism as well as the reliance on domestic anti-abuse legislation will be considered. Another major topic of the course will be the importance of the cooperation between tax administrations under the exchange of information provisions of treaties. Students will get a feeling of where the borderline has to be drawn between legal and illegal international tax planning.
F 11/12: March 30-31, 2012 F 12/13: February 1-2, 2013 P 11/13: March 30-31, 2012
Controlled Foreign Corporation Rules: Selected Contemporary Issues (2)

Avi-Yonah, Reuven, F 12/13 Harris, Peter A., F 11/12, P 11/13 The last two decades have seen a dramatic increase in the number of countries adopting controlled foreign corporation rules (CFC rules). Despite a conceptual connection with the domestic tax shelter problem, CFC rules tend to apply only in an international setting. Further, the manner in which these rules are implemented from country to country shows a lack of uniformity. These features raise serious questions as regards the interaction between CFC rules and tax treaties and EU law. The main objective of these lectures is to gain an understanding of the policy underlying CFC rules, particularly within a broader conceptual perspective. The lectures will explore from a comparative view the approaches that countries take in implementing CFC rules. They will also explore the core issues that CFC rules raise in the context of tax treaties and EU law.
F 11/12: February 17-18, 2012 F 12/13: November 30 December 1, 2012 P 11/13: February 17-18, 2012
Full
stu -time
dent
s 09/
10
43
Course contents
US CFC, LOB and other Anti-Avoidance Rules (2)
Brauner, Yariv, F 11/12, P 11/13 The United States taxes its residents on a worldwide basis. At the same time, it grants outbound investors two forms of tax benefits: deferral of taxation of income earned by foreign corporations owned by United States residents, and a unilateral (direct and indirect) credit for foreign taxes paid. The rhetoric behind these benefits is that they help the competitiveness of United States corporations and maintain the preferable policy of capital export neutrality. These benefits, however, are considered extraordinary, and as such, the United States employs a large variety of specific anti-abuse or anti-avoidance mechanisms (note that the US, as a matter of principle, has no general anti-avoidance standard). The benefit of deferral, for instance, is paired with certain anti-deferral mechanisms; the most important of them is subpart F, which deals with Controlled Foreign Corporations (CFC). The United States treaty policy takes a similar stance regarding the concessions made in double tax conventions, attempting to guarantee the integrity of its treaties as bilateral agreements that represent specific compromises between the treaty partners, and only between them. The long-standing insistence of the United States on including specific limitation of benefits (LOB) clauses in its treaties is the most notable example of this policy. The lecture will discuss the general United States anti-avoidance policy and the various particular mechanisms to allow better understanding of both the opportunities and risks involved in US outbound investment.
F 11/12: January 20-21, 2012 P 11/13: January 20-21, 2012
International tax policy (4)
Comparative Corporate Tax Policies (2)

Garbarino, Carlo, F 12/13, P 11/13 The course is aimed at those students who, having taken domestic and international tax courses, are interested in understanding how tax systems compete and evolve: the course provides an introduction to the comparative dimensions of tax law and endeavors to bridge the gap between domestic and international taxation. We will focus mainly on selected issues of corporate taxes having an international impact and use a comparative approach to analyze the evolution and circulation of tax models (intra-group dividends, tax leverage, tax consolidation, corporate reorganizations). In this approach, tax reforms are viewed as the result of the selection through legal transplants and similar techniques, by domestic policy-makers, of alternative solutions circulating in the market for tax ideas. We will see how domestic systems can be viewed as the outcome of competitive evolution and traced back to tax models addressing common policy issues. We will also consider certain top-down constraints in the EU process of tax coordination, with specific attention to the so-called negative integration prompted by the leading cases of the European Court of Justice in tax matters protecting the four freedom enshrined in the EC Treaty. We will study the arguments and the reasoning adopted by the ECJ in these cases and their impact on domestic legislation and tax policy. Finally, we will combine the comparative/evolutionary approach and the case method to depict an evolutionary map for EU corporate taxes which reveals a common core in respect to cross-border tax consolidation of groups of companies; within this framework we will consider the EU proposal for a common consolidated corporate tax base (CCCTB) and the US proposals for adopting formulary apportionment.
F 12/13: February 15-16, 2013 P 11/13: February 15-16, 2013
44
Course contents
Tax Policy and Planning in Europe (2)
Spengel, Christoph, F 11/12 Enterprises operating across borders in Europe are confronted with heterogeneous corporate taxation despite EU-wide tax harmonization. This can be mainly put down to the fact that tax sovereignty has basically rested with the Member States, despite competences being passed on to the European Union. Within their retained national sovereignty, in line with targets defined by them and according to their traditions, the Member States collect taxes differently. Enterprises have to adapt their organization, finance and channels of distribution to the range of tax conditions in the Member States and aim to optimize their tax situation by considering all other company objectives. With the help of case studies, this course looks at determining goals and means of tax planning within the EU.
F 11/12: February 24-25, 2012
Trends in EU Tax Law (1)

Heydt, Volker / Hohenwarter-Mayr, Daniela, F 11/12 Schn, Wolfgang, F 12/13, P 11/13 The current trends in EU tax law and the potential for enhancing a common tax policy will be examined in the light of the experience of the previous decades. In doing so, the main emphasis is on direct taxes. The budgetary autonomy of the individual Member States will have to be balanced against tax harmonization in the Internal Market, as well as the demands of the European Union to have its own financial resources. This course will tackle the conflicts between national sovereignty and Europeanization, as well as between the subsidiarity principle and the increasing need for EU-wide coordination as a result of ECJ decisions.
F 11/12: May 12, 2012 F 12/13: March 9, 2013 P 11/13: March 9, 2013
Full
stu -time
dent
s 09/
10
45
Course contents
WTO and Tax Policy (1)
daly, Michael, F 12/13, P 11/13 van Thiel, Servaas, F 11/12 Tariffs and other indirect taxes, whether applied at the border or internally, have long been subject to the binding multilateral rules embodied in the General Agreement on Tariffs and Trade (GATT). But in recognition of the fact that tax measures can be used as substitutes for other types of protection and government assistance, direct as well as indirect taxation has come under increased scrutiny at the World Trade Organization (WTO). This recognition is reflected in several of the multilateral agreements negotiated under the Uruguay Round, notably those concerning subsidies and trade-related investment measures (TRIMs). These new agreements reflect the growing realization by national governments that multilateral rules need to play an increasingly important role in regulating the use of tax measures, especially where these measures affect the international movement of goods, services, capital and persons. As a consequence of these agreements, disputes concerning taxation are becoming more frequent at the WTO. In particular, the widely-followed ruling by the WTOs Dispute Settlement Body against the United States concerning the latters FSC/ ETI scheme, which led to the largest retaliation award ever authorized in a dispute at the WTO, confirmed (if there were ever any doubt) that, generally speaking, direct taxes, like indirect taxes (including tariffs), are subject to the multilateral rules of the WTO, notwithstanding efforts by tax authorities to secure specific exemptions for certain direct tax measures in these agreements. This ruling reconfirmed the traditional distinction under multilateral trade rules between direct and indirect taxes, especially with respect to how such taxes should be treated under the subsidy and border tax adjustment rules of the WTO. It would be not surprising if other WTO-inconsistent direct tax measures were identified in the future, leading to further disputes among WTO members. Multilateral WTO rules can therefore be expected to continue to be an important factor in shaping members tax policies, as they will undoubtedly want to avoid having their tax policies successfully challenged in the WTO. This lecture provides an overview of the main rationale for the WTO, the fundamental principles (non-discrimination, predictability and transparency) underlying its rules, and extent to which taxation is subject to these rules. It also refers to some selected disputes between members and rulings by the WTO. In addition, it focuses on some tax measures that do not necessarily contravene WTO rules, but nonetheless affect the international movement of goods, services, c apital and persons.
F 11/12: March 29, 2012 F 12/13: June 1, 2013 P 11/13: June 1, 2013
Supplementary courses (6)
European Company Law (1)

Kalss, Susanne, F 11/12 Kersting, Christian, F 12/13, P 11/13 The aim of the lecture is to give students an overview of European company law and related fields of European capital markets law. The lecture begins with an introduction to the relevant statutory provisions (provisions in the EC Treaty, directives, regulations and recommendations). It then focuses on the European harmonization directives and tries to outline the main issues of European company law (registration, representation, protection of creditors and minority shareholders, merger and de-merger, accounting and auditing). The lecture also deals with the relevant decisions of the ECJ and takes a closer look at the European forms of companies (e.g. SE, SCE).
F 11/12: May 25, 2012 F 12/13: March 23, 2013 P 11/13: March 23, 2013
46
Course contents
IAS and IFRS (2)
dArcy, Anne / Eberhartinger, Eva, F 11/12, F 12/13, P 11/13 Financial reporting is becoming increasingly standardized. The course provides an overview of the current international developments in this area. IAS/IFRS are at the heart of this course. In particular, questions relating to financial statements, recognition and measurement, and financial statement analysis will be discussed. The possible tendering processes for financial statements under IAS/IFRS will be compared and discussed.
F 11/12: May 31 June 1, 2012 F 12/13: May 23-24, 2013 P 11/13: May 31 June 1, 2012
International Social Security Law (1)

Eichenhofer, Eberhard, F 11/12 Pennings, Frans, F 12/13, P 11/13 Social security and taxes are two sides of state activity today; the latter is required, so that the first can be made possible. All advanced economies and societies provide for public benefits not only for persons in need, but at the same time for persons exposed to social risks. The international guarantees for the social security system can be found at the level of the UN, but at the same time at the levels of both the Council of Europe and the European Union. A specific role in the worldwide guarantee of social security rights is played by the International Labour Organisation (ILO). It has set Minimum Standards of Social Security and has devoted much time to setting out international rules on the coordination of national social security systems. The most advanced type of such a co-ordination system can be found in the EU legislation. Enacted in Regulation 883/2004, social security systems of all EU Member States and the ones of the European Economic Space are interrelated in a sophisticated framework of legal rules and principles. The course focuses on the concept, the history and the main principles of international social security law. It is predominantly emphasizing the rules and principles of the EU social security co-ordination law as it is elaborated in Regulation 883/2004. These rules will be outlined by referring to the leading cases on this very important piece of EU legislation.
F 11/12: November 24, 2011 F 12/13: May 31, 2013 P 11/13: May 31, 2013
International Tax English (2)

Nettinga, Margaret, F 11/12, F 12/13, P 11/13 English-language communication skills are important both for a successful LL.M. study and in tax practice. Tax experts communicate with one another through a common tax language and have to be able to clearly explain technical terms to clients. This course provides an introduction to the use of tax English and in particular to some of the terms students will encounter during their LL.M. studies. Tools for writing effective legal and tax English will be offered and the pitfalls in writing and speaking about tax will be discussed. Although the emphasis is on written English, role-playing and speaking skills are also an important part of the course.
F 11/12: September 16-17, 2011 F 12/13: September 7-8, 2012 P 11/13: September 9-10, 2011
47
Course contents
Master thesis (12)
Exchange of Information
Seer, Roman, F 12/13 In a globalized tax world the national means of the tax authorities are limited and are not sufficient to effect tax claims. An increasing number of legal sources exists to overcome the gap between the worldwide taxation and the limited territorial power of the national tax authorities: e.g. EU Council directives concerning mutual assistance in the field of direct taxation and for the recovery of claims, EU Council regulations on administrative cooperation in the field of Value Added Tax (VAT), Art. 26, 27 OECD Tax Treaty Models as patterns for bilateral agreements of information exchange and mutual assistance in the tax collection, the OECD Model 2002 for a specific bilateral Tax Information Exchange Agreement (TIEA) which was recently used for agreements with tax haven countries, the Convention of the Council of Europe/OECD on mutual administrative assistance in tax matters of January 25, 1988 and unilateral legal sources. It is necessary to distinguish between these different multinational, EU-, bi- and unilateral layers of law. The lecture aims to provide the systematic understanding for the content, scope and relationship of these legal sources. Furthermore, the lecture will show the tension between the need for an efficient exchange of information, on the one side, and the need of legal protection of the taxpayer against violation of his commercial or professional secrets, on the other.
F 12/13: October 26-27, 2012
Exchange of Information Seminar II and Seminar III

Gnther, Oliver-Christoph / Tchler, Nicole, F 12/13 Both of these courses are directly linked to the introductory class on this topic and will be held while students are working on their Masters theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research and using the international tax literature. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.
F 12/13: seminar II: January 11-12, 2013 F 12/13: seminar III: April 5-6, 2013
time Part-
class
07/0
48
Foto Weinwurm
Course contents
International Group Financing
Storck, Alfred, F 11/12 International group financing will be discussed and analyzed from various aspects. From a corporate perspective international group financing is an integral part of business and finance planning with tax planning and tax risk management included. External financing on capital markets often requires specific structures with finance companies to minimize taxes (seen as cost). Internal capital structures and financings raise a number of specific tax issues. From a corporate perspective debt financing allows reducing/optimizing the groups tax charge. From the tax authorities perspective, leverage reduces revenues and therefore specific tax rules provide for limitations on the deductibility of interest. From an international tax law perspective, qualification conflicts between various financing alternatives (including hybrid structures) may occur, causing double taxation or non-taxation. From a transfer pricing perspective, the arm`s length principle has to deal with the volumes of debt financing and the appropriate interest levels. The content of the lecture therefore covers (I) principles of taxation for multinational companies and its impact for financing, (II) financing of a multinational group (company) versus intra-group legal entity capitalizations/financings, (III) external group financing and taxes (including finance companies), (IV) intra-group financings and loans/deposits (including thin cap rules), (V) intra-group financings and cash pools, (VI) arms length interest level and the risk factor.
F 11/12: October 14-15, 2011
International Group Financing Seminar II and Seminar III

Massoner, Christian / Strzlinger, Birgit, F 11/12 Both of these courses are directly linked to the introductory class on this topic and will be held while students are working on their Masters theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research and using the international tax literature. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.
F 11/12: seminar II: January 13-14, 2012 F 11/12: seminar III: April 13-14, 2012
The real benefit was to make friendships that will last as long as we live. Tams Fehr, Hungary, Full-time 06/07 CMS Cameron McKenna LLP, Budapest
49
Course contents
Limits to Tax Planning from a Perspective of Community Law
De Broe, Luc, P 11/13 Tax law contains many anti-abuse provisions. In the European Union these provisions must be in accordance with Community law. Accordingly, further study of abuse concepts in European tax law is useful and desirable. This lecture will deal with the creation of and the content of the abuse concepts. The starting point of the discussion will be the ECJs case law on abuse of Community law in non-tax matters. Thereafter, the focus will be on abuse in direct and indirect taxation in the EU. We shall discuss how the European Court of Justice treats abuse, the differences and similarities between the various abuse concepts, and if so to what extent, tax jurisdiction shopping is allowed.
P 11/13: October 20-21, 2011
Limits to Tax Planning from a Perspective of Community Law Seminar II and Seminar III
Simader, Karin / Titz, Elisabeth, P 11/13 Both of these courses are directly linked to the introductory class on this topic and will be held while students are working on their Masters theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research and using the international tax literature. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.
P 11/13: seminar II: February 24-25, 2012 P 11/13: seminar III: September 14-15, 2012
The program was a door opener and crucial for my professional career. Andreas Kapferer, Austria, Full-time 99/00 Partner, Deloitte Austria
50
Alumni
Alumni association
Bringing alumni together is the mission and identity of the Alumni Association. The annual Reunion encourages a feeling of community, offers networking opportunities and helps to maintain connections with the Vienna LL.M. program and among alumni. As of June 2010 we have 389 graduates from 47 different countries: Argentina, Belgium, Brazil, Bulgaria, Canada, Chile, China, Czech Republic, Estonia, Finland, France, Germany, Greece, Hungary, India, Indonesia, Italy, Japan, Kenya, Lithuania, Macedonia, Malta, Malaysia, Mexico, Moldova, Morocco, Norway, Peru, Poland, Portugal, Romania, Russia, Serbia, Slovakia, Slovenia, South Africa, Spain, Switzerland, Taiwan (ROC), Tanzania, the Netherlands, Turkey, Ukraine, USA, Uzbekistan, Venezuela and Austria.
Part-time g
raduates 07
/09
Full-time g
raduates 07
/08
Activities
The annual official Alumni Reunion takes place in October. It is an inspiring mixture of scientific and social events, including lectures, discussions and a delightful excursion in the afternoon. The day preceding the Reunion is dedicated to Klaus Vogel, who was instrumental in developing this LL.M. program. The Klaus Vogel Lecture was established in 2007 as a reflection of his excellent reputation worldwide as an expert in international tax law. The Lecture takes place every year and is open to current students, graduates of this program and tax experts from all around the world.
/10
Finally, the Vienna LL.M. Alumni News appears twice yearly and highlights the study program, with items on lectures, student life and graduates careers after finishing the LL.M. program.
Full-time g
raduates 09
51
Calendar full-time program 2011/2012

December
New Years Eve Transfer Pricing, p.35 Transfer Pricing, p.35 German Tax Law, p.30 Tax Law of the Netherlands, p.31 Epiphany Corpus Christi Immaculate Conception VAT Planning, p.39 Easter Monday European Tax Planning, p.38 Mergers in Europe, p.37 Various course exams Trends in EU Tax Law, p.45 Group Financing, seminar II, p.49 Group Financing, seminar II, p.49 Various course exams US Tax Law, p.31 US Tax Law, p.31 CFC Rules, p.43 Various course exams US CFC, LOB, Anti-Avoidance, p.44 US CFC, LOB, Anti-Avoidance, p.44 Tax Planning Tools, p.39 Tax Planning Tools, p.39 Tax Policy in Europe, p.45 Christmas Day Christmas Eve The Negotiation of Tax Treaties, p.35 The Negotiation of Tax Treaties, p.35 WTO and Tax Policy, p.46 Abuse of Tax Treaties, p.43 Abuse of Tax Treaties, p.43 IAS and IFRS, p.47 Indian Tax Law, p.30 Indian Tax Law, p.30 Tax Policy in Europe, p.45 European Company Law, p.46 Tax Planning in France, p.37 Whit Sunday Whit Monday CFC Rules, p.43 Various course exams Tax Planning in the US, p.39 Tax Planning in the US, p.39 Tax Policies in the EU, p.42 Tax Policies in the EU, p.42 Tax Policies in the EU, p.42 Ascension Day Financial Instruments, p.36 Conflict Settlement, p.32 Group Financing, seminar III, p.49 Group Financing, seminar III, p.49 Dual Residence, p.32 Various course exams Various course exams Easter Sunday Holding Companies, p.36 Holding Companies, p.36 Tax Planning in Japan, p.37 Various course exams Tax Planning in Japan, p.37 Various course exams National Holiday IAS and IFRS, p.47
September 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
October
November
January
February
March
April
May
June
Austrian Tax Law, p.29
All Saints Day
Various course exams
Comparative Tax Law, p.30
The EU: Legal and Insti- tutional Framework, p.42
10
11
Belgian Tax Law, p.29
12
Tax Law of the Nordic Countries, p.31
13
14
Group Financing, p.49
15
Group Financing, p.49
16
International Tax English, p.47
17
EU and Third Countries, p.40
18
EU and Indirect Taxation, p.40
19
20
21
Tax Treaty Interpretation, p.34
22
Principles of Tax Treaty Law, p.33
Tax Treaty Interpretation, p.34
23
24
International Social Security Law, p.47
25
Taxation of Entertainers and Athletes, p.35
26
National Holiday
Taxation of Entertainers and Athletes, p.35
27
28
ECJ Case Law, p.40
29
ECJ Case Law, p.40
30
31
Calendar full-time program 2012/2013

December
CFC Rules, p.43 New Years Eve Abuse of Tax Treaties, p.43 International Mergers and Acquisitions, p.36 Various course exams Exchange of Information, seminar III, p.48 Epiphany US Tax Law, p.31 US Tax Law, p.31 Trends in EU Tax Law, p.45 Tax Policies in the EU, p.42 Exchange of Information, seminar II, p.48 Exchange of Information, seminar II, p.48 Various course exams Tax Planning in the US, p.39 Tax Planning in the US, p.39 Comparative Coporate Tax Policies, p.44 Various course exams South American Tax Treaty Policy, p.33 Tax Planning in South America, p.38 Various course exams Australian Tax Law, p.29 Australian Tax Law, p.29 Swiss Tax Law, p.31 French Tax Law, p.30 Whit Sunday Whit Monday Tax Planning Tools, p.39 Various course exams Permanent Establishments, p.33 Tax Treaty Developments, p.34 European Company Law, p.46 IAS and IFRS, p.47 IAS and IFRS, p.47 Christmas Day Christmas Eve Abuse Concepts, p.42 Abuse Concepts, p.42 Taxation of Entertainers and Athletes, p.35 Taxation of Entertainers and Athletes, p.35 Australian Tax Treaty Policy, p.32 Tax Planning Tools, p.39 Comparative Coporate Tax Policies, p.44 Tax Policies in the EU, p.42 Tax Policies in the EU, p.42 Various course exams Holding Companies, p.36 Holding Companies, p.36 Various course exams Developed and Less Developed Countries, p.34 Ascension Day Various course exams Exchange of Information, seminar III, p.48 Qualification Conflicts, p.37 Various course exams Tax Planning in Multi- national Companies, p.38 Easter Monday National Holiday Abuse of Tax Treaties, p.43 Tax Planning in Multi- national Companies, p.38 WTO and Tax Policy, p.46
September 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Corpus Christi Easter Sunday International Social Security Law, p.47
October
November
January
February
March
April
May
June
All Saints Day
The Negotiation of Tax Treaties, p.35
German Tax Law, p.30
10
Tax Law of the Nordic Countries, p.31
11
12
Principles of European Tax Law, p.41
13
EU State Aid Rules, p.41
14
15
16
17
18
19
The Relevance of OECD Documents, p.35
20
21
22
23
Principles of International Tax Planning, p.36
24
European Tax Planning, p.38
25
26
Exchange of nformation, I p.48
27
Exchange of Information, p.48
28
ECJ Case Law, p.40
29
ECJ Case Law, p.40
30
CFC Rules, p.43
30 31
31
2011 Calendar part-time program 2011/2013

December
New Years Eve National Holiday Various course exams Various course exams German Tax Law, p.30 Tax Law of the Netherlands, p.31 Epiphany Corpus Christi Immaculate Conception Easter Monday Easter Sunday IAS and IFRS, p.47 Transfer Pricing, p.35 Transfer Pricing, p.35
2012
April 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Dual Residence, p.32
September
October
November
January
February
March
May
June
All Saints Day
10
11
12
13
14
15
US Tax Law, p.31 US Tax Law, p.31 CFC Rules, p.43 Various course exams US CFC, LOB, Anti-Avoidance, p.44 US CFC, LOB, Anti-Avoidance, p.44 CFC Rules, p.43 Tax Planning in the US, p.39 Tax Planning in the US, p.39 Tax Policies in the EU, p.42 Tax Policies in the EU, p.42 Tax Policies in the EU, p.42 Ascension Day Financial Instruments, p.36 Conflict Settlement, p.32
15
16
16 17 18 19 20 21
Tax Planning Tools, p.39 Tax Planning Tools, p.39
17
EU and Third Countries, p.40
18
EU and Indirect Taxation, p.40
19
20
Limits to Tax Planning, p.50
21
Limits to Tax Planning, p.50
22
22 23
Limits to Tax Planning, seminar II, p.50
23
24
Christmas Day Christmas Eve
24
Limits to Tax Planning, seminar II, p.50
25
25 26
Whit Sunday Whit Monday
26
National Holiday
27
27 28 29
Abuse of Tax Treaties, p.43 Abuse of Tax Treaties, p.43 IAS and IFRS, p.47
28
29
30
30 31
31
2012 Calendar part-time program 2011/2013

December
New Years Eve Tax Planning in Multi- national Companies, p.38 International Mergers and Acquisitions, p.36 Various course exams Tax Planning in Multi- national Companies, p.38 Easter Monday National Holiday WTO and Tax Policy, p.46
2013
April 1 2 3 4 5 May June
September
October
November
January
February
March
All Saints Day
5
Epiphany Various course exams Immaculate Conception Trends in EU Tax Law, p.45 Developed and Less Developed Countries, p.34 Ascension Day
6 7 8 9 10 11
Various course exams Holding Companies, p.36 Holding Companies, p.36 Comparative Coporate Tax Policies, p.44 Comparative Coporate Tax Policies, p.44 Various course exams
10
11
12
12 13 14 15 16
Swiss Tax Law, p.31
13
14
Limits to Tax Planning, seminar III, p.50
15
Limits to Tax Planning, seminar III, p.50
16
Various course exams South American Tax Treaty Policy, p.33 Tax Planning in South America, p.38
17
17
Various course exams Australian Tax Law, p.29 Australian Tax Law, p.29 French Tax Law, p.30 Whit Sunday Whit Monday
18
18 19 20 21
Tax Treaty Developments, p.34 European Company Law, p.46
19
20
21
22
22 23 24
23
Principles of International Tax Planning, p.36
24
Christmas Day Christmas Eve
European Tax Planning, p.38
25
25 26 27 28 29
Corpus Christi Easter Sunday International Social Security Law, p.47
26
National Holiday
27
28
ECJ Case Law, p.40
29
ECJ Case Law, p.40
30
30 31
31
Registration
Deadlines
The deadline for applications for the 2011/2012 full-time program and the 2011/2013 parttime program is April 15, 2011. The academic director assesses each application by April 30, 2011 and will base his decision on the applicants qualifications and the order in which the applications were received. All successful applicants must pay a registration fee of EUR 1,000, which will be deducted from the total program fee, by May 31, 2011. The remainder of the program fee must be transferred by July 31, 2011 at the latest. Applications for the 2012/2013 full-time program must be submitted by April 15, 2012. A decision on the applications will be made by April 30, 2012. The registration fee must be paid by May 31, 2012 and the remaining program fee must be transferred by July 31, 2012.
Refund
The registration fee cannot be refunded if an applicant decides to withdraw from the program before commencement. There is also no refund of the program fee for applicants who withdraw from the program after it begins.
Required documents
The following documents copies are sufficient must be submitted: Signed application form Curriculum vitae / rsum University certificates and diplomas One colored passport-sized photo (with name and signature on the back) Certificates from internships, practical experience / training, additional qualifications, periods abroad, etc. It is recommended that applicants provide the results of a TOEFL test or a similar assessment of language skills. Documents not in German or English should be accompanied by an official, certified translation into German or English.
Return to
Please submit your application including the requested documents to: Akademie der Wirtschaftstreuhnder Attn. Barbara Ender-Rochowansky Schnbrunner Strae 222-228/1/6/3 1120 Vienna Austria
56
Application form
I hereby submit my application for enrolment in the LL.M. Program in International Tax Law and have chosen the following program: 2011/2012 full-time program 2012/2013 full-time program 2011/2013 part-time program
Please write clearly using block letters.
Surname ................................................................................................................................................................................................................................................................................. First name ........................................................................................................................................................................................................................................................................... Academic degree (e.g. BA, MA, JD, Mag., Dr.) .................................................................................................................................................. Date of birth .................................................................................................................................................................................................................................................................. Place of birth ................................................................................................................................................................................................................................................................. Sex
male
female
Nationality ......................................................................................................................................................................................................................................................................... Occupation ........................................................................................................................................................................................................................................................................
Private details Postal address ............................................................................................................................................................................................................................................................. ZIP code, city ................................................................................................................................................................................................................................................................ Country ................................................................................................................................................................................................................................................................................... Phone ......................................................................................................................................................................................................................................................................................... Fax .................................................................................................................................................................................................................................................................................................. E-mail ..........................................................................................................................................................................................................................................................................................
57
Work details Company ........................................................................................................................................................................................... Position ................................................................................................................................................................................................ Postal address .......................................................................................................................................................................... ZIP code, city ............................................................................................................................................................................. Country ................................................................................................................................................................................................ Phone ...................................................................................................................................................................................................... Fax ............................................................................................................................................................................................................... E-mail .......................................................................................................................................................................................................
How did you learn about our program? Internet Brochures / folders Newspaper WU Graduates of our program Family / friends / colleagues Other (please specify): .........................................................................................................................................................
I hereby agree that, if selected, I will pay the registration fee of EUR 1,000 for the 2011/2012 full-time program and the 2011/2013 part-time program by May 31, 2011 (2012/2013 fulltime program by May 31, 2012) and the remainder by July 31, 2011 (2012/2013 full-time program by July 31, 2012). I accept the refund policy as laid down on page 56.
..............................................................................................................................................................................................................................
Date, Signature
58
cement advan Your in law wledge of kno

Gericht stoppt Flugannullierung Seite 9
Rechtspanorama
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Wirtschaftsrecht i sterreich und CE

www.cms-rrh.com
Steuern und Wirtschaft Seite 10
Rechtspanorama
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Freier Uni-Zugang: Druck auf sterreich wch

Wirtschaftsrecht in
VON STEFAN BROCZA
WIEN. Morgen, Dienstag, wird der Europische Gerichtshof (EuGH) in Luxemburg wieder ein Urteil zum Themenbereich Zugangsbeschrnkungen fr auslndische Studenten verknden (C-73/08). Diesmal ist Belgien das beklagte Land. Auf dem Prfstand stehen Regelungen, die den Ansturm franzsischer Studenten in bestimmten Gesundheitsstudienrichtungen (etwa Bachelorstudium fr Hebammen, Ergotherapie, Logopdie, aber auch Veterinrmedizin) verhindern sollen. hnlich wie sterreich, das mit immer greren Zahlen von deutschen Numerus-clausus-Flchtlingen konfrontiert ist, sieht sich der franzsischsprachige Teil Belgiens zunehmend von Studenten aus Frankreich berrollt. Die zur Diskussion stehenden Bestimmungen diverse Wohnsitz- und Aufenthaltserfordernisse werden morgen (wieder einmal) vom EuGH als diskriminierend und somit mit dem Europarecht als unvereinbar erkannt. Der Gerichtshof sieht Artikel 12 EG-Vertrag (heute: Artikel 18 AEUV; Diskriminierungsverbot) sowie Artikel 18 EG-Vertrag (heute: Artikel 21 AEUV) verletzt. So weit nichts Neues. Schon in der Vergangenheit ist auch sterreich mit seinen Regelungen am EuGH gescheitert (s. etwa das Urteil vom 7. Juli 2005, C-147/03).
EU-RECHT. Belgien droht eine Verurteilung, weil es Studenten aus anderen EU-Staaten diskriminiert. Aber au sterreich und CEE sterreichische Regelung ist problematisch. Sinnvoll wre es daher, neue Argumente und Verbndete zu su www.cms-rrh.com
Steuern und Wirtschaft Seite 12
Rechtspanorama
SEITE 9 //// MONTAG, 22. MRZ 2010 //// DIEPRESSE.COM/RECHTSPANORAMA VON PHILIPP AICHINGER
WIEN. Mit 1. Juli 2008 begann eine neue Zeitrechnung im Asylverfahren. Die Grndung des Asylgerichtshofs war notwendig geworden, weil seine Vorgngerinstitution (der Unabhngige Bundesasylsenat, kurz Ubas) mit bis zu 28.000 Verfahren berlastet war. Ein Unternehmen htte wahrscheinlich Konkurs anmelden mssen, erklrte Harald Perl, Prsident des Asylgerichtshofs und zuvor Chef des Ubas. Der neue Asylgerichtshof wurde aber mit ausreichend Personal ausgestattet. Jetzt ist der Verfahrensrucksack bereits zur Hlfte abgebaut, bilanzierte Perl beim letztwchigen Rechtspanorama am Juridicum, zu dem die Wiener juridische Fakultt und die Fachgruppe Grundrechte der Richtervereinigung zusammen mit der Presse eingeladen hatte. Und bei den neu anhngig gewordenen Verfahren knne man die Hlfte bereits innerhalb von sechs Monaten erledigen, so Perl. Die Freude ob der schnelleren Verfahren hielt sich bei manch anderem Vertreter am Podium aber in Grenzen. Was ist denn der Grund fr die Beschleunigung?, fragte Karin Keil von der Caritas. Flle aus dem Kosovo oder Tschetschenien wrden zum Beispiel nur mehr wenig verhandelt werden, so Keil. Den Kosovo habe man zum sicheren Drittstaat erklrt. Und in Tschetschenien sei die Situation jetzt zwar sicher eine andere als frher, aber nicht unbedingt eine bessere, meinte Keil. Auch politisch ttige Kurden htten seit Juli 2008 kaum noch Chancen auf Asyl. Ein weiterer Kritikpunkt: Aus unserer Sicht ist die Rechtsprechung des Asylgerichtshofs nicht einheitlich. Bei gleich gelagerten Fllen wird anders entschieden, kritisierte Keil. Auch Gerhard Muzak, Verwaltungsrechtsprofessor an der Uni Wien, warnte: Ich habe das Gefhl, der Asylgerichtshof wird an seiner Entscheidungszahl gemessen. Das halte ich fr sehr problematisch, betonte Muzak. Wichtiger sei, dass die Entscheidungen das rechtsstaatliche Niveau aufweisen, das man von einem Hchstgericht erwarte. Das war bei sehr vielen Entscheidungen der Fall. Es gibt aber auch Entscheidungen, bei denen man das bezweifelt. berdies sei es zu einer gnzlichen Ausschaltung
Kabarettisten sind keine Terroristen

Wirtschaftsrecht in
VON PHILIPP AICHINGER
PRVENTIONSGESETZE. Das Verchtlichmachen von Personen wird doch nicht als terroristisches Delikt eingestuft. sterreich und CEE Strafbar ist es aber knftig, die Wrde von Behinderten, Pensionisten oder Homosexuellen ffentlich zu verletzen. www.cms-rrh.com
Asylrecht wurde nicht strenger, nur dmmer
PRESSE-DISKUSSION. Der vor knapp zwei Jahren gegrndete Asylgerichtshof beschleunigte die Verfahren. Doch Kritiker beanstanden, dass darunter die Qualitt leidet. Auch die vielen Gesetzesnovellen wrden unntig Verwirrung stiften.
Schwieriger Aufstieg zum Asyl.

des Verwaltungsgerichtshofs (VwGH) gekommen. Dieser darf nmlich seit Juli 2008 nicht mehr vom Asylwerber selbst angerufen werden. Nur der Asylgerichtshof selbst und das Innenministerium knnten den VwGH um eine Grundsatzentscheidung bei neu auftauchenden Fragen ersuchen. Allerdings hat das bis dato noch niemand gemacht. eine Entscheidung bei 20.000 Fllen ist immer noch sehr wenig, konterte Muzak. Eine Kehrseite der Reform ist die starke Belastung des Verfassungsgerichtshofs (VfGH). Viele Asylwerber berufen dort gegen Entscheidungen des Asylgerichts, weil der Weg zum VwGH untersagt ist. Bereits 63 Prozent des Gesamtanfalls am VfGH wrden Asylsachen betreffen, erklrte Kurt Heller. Der einstige Verfassungsrichter er schied mit Jahreswechsel aus Altersgrnden aus hatte die Asylthemen am VfGH federfhrend bearbeitet. Den Sinn der 2008 erfolgten Reform versteht Heller aber nicht. Der VwGH wurde ausgeschaltet, das hat dazu gefhrt, dass der Rucksack an Fllen auf den VfGH bertragen wurde. Was das fr einen Sinn machen soll, wei ich nicht, meinte Heller. Schlielich gebe es am VwGH viel mehr Richter als am VfGH. Heller erlaubte sich auch, einen subjektiven Verdacht zu uern: Vielleicht, so Heller, sei es manchen gar nicht unrecht, wenn der VfGH durch die berlastung seinen ei-
Der Notfallparagraf als Rettung vor den Deutschen view. sses Law Re y in Die Pre sterreichische Every Monda Zeitschrift fr its applied: P d h ll as law anegerechtow austrian papers as we scoop about all local news Get the rama and the insight of /rechtspano nsive weekly .com the most exte at diepresse rrent articles continues cu newsletter. htspanorama Rec in culty of Law held at the fa s are . n discussion dical debatte addition ope In ffer lively juri raz which o or Vienna and G e for 3 weeks Sonntag fre am . d Die Presse ro per month ie Presse an only 21,50 Eu Test D n for t subscriptio get a studen
Zwei Richter, eine Meinung
Und noch etwas findet Muzak merkwrdig: Obwohl am Asylgerichtshof immer zwei Richter gemeinsam entscheiden mssen, seien sich beide immer einig gewesen. Im Falle einer Nichteinigung der beiden Richter wrde der Fall auf einen Fnfer-Senat bergehen. Nun sah sich Gerichtschef Perl veranlasst, seine Institution zu verteidigen: Ich kann Ihnen besttigen, dass in den Zweier-Senaten jeden Tag intensive Diskussionen stattfinden, betonte er. berdies gebe es gerade ganz aktuell die erste Entscheidung eines Fnfer-Senats, weil sich zwei Richter nicht einigen konnten. Aber
WIEN. Morgen, Dienstag, will der Ministerrat die neuen Antiterrorgesetze beschlieen. Der ursprngliche Entwurf von Justizministerin Claudia Bandion-Ortner war von mehreren Seiten als berschieend kritisiert worden. Auch die SP wollte nicht zustimmen. Der Presse liegt der berarbeitete und mit der SP abgesprochene Entwurf vor. Dieser sieht Przisierungen vor, bleibt aber nicht unumstritten. nderungen gab es zum Beispiel beim Delikt der Verhetzung. Dieses begeht, wer ffentlich zu Gewalt oder feindlichen Handlungen gegen bestimmte Bevlkerungsgruppen auffordert oder Hetze betreibt. Es reicht aber auch, wenn man Mitglieder der geschtzten Gruppen derart verchtlich macht, dass die Menschenwrde verletzt wird. Das Delikt ist nicht neu. Nach den ursprnglichen Plnen sollte es aber in die Liste der terroristischen Straftaten aufgenommen werden. Damit knnte unter gewissen Umstnden eine hhere Haftstrafe verhngt werden. Von diesem Plan rckt der neue Entwurf ab. Also drohen fr Verhetzung ( 283 des Strafgesetzbuchs) Schluss mit lustig? weiterhin maximal zwei Jahre Haft. Ausgeweitet wird aber wie geplant der Kreis der geschtzten Wien. Da bereits das VerchtlichGruppen. Angehrige einer be- machen strafbar sei, wre eine Anstimmten Religion, einer Rasse, klage gegen Kabarettisten mglich, eines Volks oder eines Staates meint sie. Das Risiko besteht, durften wegen der Zugehrigkeit sagt die Juristin zur Presse. zu dieser Gruppe bereits bisher berdies sei sterreich durch innicht verchtlich gemacht werden. ternationale Vorgaben zwar verAuch die Gruppe als solche ist ge- pflichtet, bestimmte Gruppen vor schtzt. Knftig sind auch vercht- Verhetzung zu schtzen (etwa welich machende Worte wegen des gen der Rasse). Aber nicht alle der [ Illustration: Vinzenz Schller ] Geschlechts, des Alters, der sexuel- im Gesetz aufgezhlten Gruppielen Ausrichtung, der Weltanschau- rungen mssten wegen internatioung oder einer Behinderung un- naler Vorgaben geschtzt werden. gentlichen Aufgaben nicht nach- Beim VfGH kann man so gut wie tersagt. Sind dann Kabarettisten kommen kann. gar nicht mit Verfahrensfehlern strafbar, die ffentlich ber Spott ber Papst schon strafbar? Nicht gut kam am Podium die Frauen, Pensionisten die Rechts- wenn es bisher keine kommen, berichtete Und auch Schwule, Politik weg. Perl berichtete berBehinderte spotten? Nein, Verurteilungen von Kabarettisten oder ein anwltin Nadja Lorenz. Wie Mu(mehrere Jahre zurckliegendes) Justizministerium.Heller wrde auch meint das zak, Keil und Auch gibt, scheine bereits jetzt eine Gesprch mit einem nichtder Vergangenheit habe es in den VwGH in nher sie es befrworten, Strafverfolgung mglich. Zum bezeichneten Regierungsmitglied. wiederFlle gegeben, machen. Lo- wenn man mehrfach der Judikatur keine anrufbar zu Beispiel, Perl hatte es darauf aufmerksam renz verfolgt wurden. weil Asylwer- Papst spottet, erklrt in denen Komiker sorgt sich auch, ber den gemacht, dass die vielen anhngi- der Gruppen sei man VfGH nur Zum Schutz ber momentan beim Zerbes. Das Verchtlichmachen gen Flle am Ubas zu langen Ver- selten Verfahrenshilfe gewhrtreligisen Gruppe und ihrer berdies international verpflichtet. einer befahren fhren werden. Die Antwort: kmen. Ingeborg Zer- der mit der ist schlielich bereits Angehrigen Dem widerspricht Das konnte Da kann ich nichts bes, Strafrechtlerinbeim Gericht vertraute Hel- Strafe gestellt. machen. Praxis an der Uni jetzt unter Noch hrter ging Heller mit den ler aber erklren. Man habe das Volksvertretern ins Gericht. Er kriti- System der Verfahrenshilfe 2008 sierte, dass mit falschen Statistiken umgestellt, berichtete er. Nun werber kriminelle Asylwerber Politik de bereits vor Gewhrung der Vergemacht werde. Die daraus resul- fahrenshilfe genau geprft, ob der tierenden Gesetzesnovellen wr- Asylwerber eine Chance auf eine den alles verkomplizieren: Das positive Entscheidung habe. Und Asylrecht wurde nicht strenger, nur bei aussichtslosen Verfahren werdmmer, bilanzierte Heller. de auch keine Verfahrenshilfe gewhrt. Es sei also nicht das RechtsRuf nach dem VwGH schutzniveau gesenkt worden, Mehrere Vertreter am Podium be- sondern es wurde die Entscheitonten auch, dass der VfGH in dung vorgezogen, so Heller. Perl hatte noch einen zentralen Asylsachen nur wenig RechtsNEU schutz gewhren kann. Denn er Appell parat: Das Wichtigste sei 2010: Einfhrungspreis es, Hefte um EUR 56, darf (im Kontrast zum VwGH) im- die Asyldebatte zu 5entemotiona(erstes Verfahren mer nur prfen, ob ein derart lisieren. Und schnelle Heft gratis) statt EUR 84, schwerer Fehler passiert ist, so sollten dazu einen Beitrag leisten, dass die Verfassung verletzt wurde. hofft der Gerichtsprsident.
Einlass nur fr inlndische Studenten?

Deutschland jedoch sehr wohl (wie von Nordrhein-Westfalen bereits angekndigt). Auch die deutsche Bildungsministerin Annette Schavan zeigte Verstndnis fr die sterreichischen Probleme. rakter habe. Es wurde blo ausgefhrt, dass das finanzielle Gleichgewicht des sterreichischen Systems der Hochschulausbildung und damit dessen Bestand selbst bedroht wrden. Wohl wissend, dass die Rechtsprechung des EuGH eine Diskriminierung aus rein wirtschaftlichen Motiven nicht anerkennt. Am Tag nach der Urteilsverkndung im Jahr 2005 wurde umgehend die nchste Regelung erlassen, die aus EU-rechtlicher Sicht problematisch ist: Fr Medizinstudienpltze wurde eine Quotenregelung erlassen (75 Prozent aller Studienpltze fr sterreicher reserviert). Eine klare Diskriminierung nach der Staatsangehrigkeit. Und wieder keine Begrndung, keine Zahlen, warum dies notwendig sei. Die Kommission verzichtet zwar derzeit auf eine Klage. sterreich ist jedoch aufgefordert, eine rechtskonforme Lsung des Hochschulzugangs zu schaffen. Nun schreiben wir das Jahr 2010. Geschehen ist bisher nichts.
[ Illustra
Und welche Verurteilungen gab es wegen des Verhetzungsparagrafen? Das Oberlandesgericht Graz wertete etwa die uerung, man habe nichts gegen Neger, jeder sollte sich einen halten, als Verhetzung (9 Bs 462/96). Auch wer von der hebrischen Hochfinanz spricht, kann strafbar sein (OLG Linz, 9 Bs 317/95). Das OLG Wien sah bei einem schwer alkoholisierten Raufbold hingegen keine Verhetzung: Er hatte die uerung Schei Zigeuner, ihr gehrt alle weggerumt, ihr werdet nie eine Ruhe haben, gettigt. Der Satz, so das Gericht, bestreite zwar das Lebensrecht der Zigeuner. Im konkreten Fall sei er aber in der Absicht der Beschimpfung vorgebracht worden (auf die Beleidigung einzelner Personen stehen maximal drei Monate) und nicht tendenzis als Appell an Gefhle gegenber Angehrigen gegnerischer Gruppen (22 Bs 181/91).
nicht diskriminierender Manahmen (etwa Aufnahmeprfung oder dem Erfordernis einer Mindestnote) begegnet werden kann. Gleichzeitig sollten der Gemeinschaftsgesetzgeber und die Mitgliedstaaten ber einheitliche Regeln fr den Bereich der Freizgigkeit der Studenten nachdenken. Abschlieend erinnert die Generalanwltin an die Ziele des EUViele Studenten als Problem Vertrags: Frderung der Solidaritt Aufhorchen lassen jedoch einige zwischen den Mitgliedstaaten soAusfhrungen und berlegungen wie die gegenseitige Pflicht zur verZusammenarbeit. der Generalanwltin Eleanor trauensvollen die Sharpston in ihrem Schlussantrag Wenn Schller ] sprachlichen Gegeben[ Illustration: Vinzenz zum morgigen Urteil (die Richter heiten und die voneinander abweifolgen in der Mehrzahl der Flle chenden nationalen Politiken im der Meinung der Generalanwl- Bereich des Zugangs zur Hochtin). Das Problem bestehe in der schulbildung zu einem besonders zu hohen Zahl der Studenten an hohen Zulauf von Studenten fhsich, nicht in der zu hohen Zahl ren, der reale Probleme im Aufnahnichtansssiger (sprich: auslndi- memitgliedstaat verursacht, seien scher) Studenten. Der unbegrenz- Aufnahme- und Herkunftsmitte und freie Zugang zur Hoch- gliedstaat dazu angehalten, sich schulbildung ist selbstverstndlich aktiv um eine vertragskonforme mglich. Allerdings mssen die Verhandlungslsung zu bemhen. Bandion-Ortner betreffenden in Gesetzen schlieen. also Bewegung in die will Lcken Mitgliedstaaten Es scheint dann auch Verfassungsrechtler BerndWIEN (aich). Die Antiterrorgesetze bereit sein, diesen auch Sache zu kommen. Dazu passen schaffen neue Delikte allenster- Christian FunkRck- auch die letzten Aussagen und in EU-Studenten ohne warnte zuletzt soreichs Strafgesetzbuch. sichtster- gar davor, dass sterreich sich zu In auf ihre Staatsangehrigkeit berlegungen des deutschen Gesundheitsministers Philipp Rsler. zu gewhren. Die Generalanwltin entwickeln reich bestehen Lcken im Kampf einem Gefngnisstaat verweist auf knnte. Die Recht- nderungen gegen den Terrorismus. Diese die bisherige nun getroffenen n- des Numerus-clausprechung derungen im neuen sus-Systems mchte ich nun schlieen, erklrt des Gerichtshofs, wo- Entwurf hlt wrden zwar keine nach einer der Experte fr nicht direkte Entlastung fr sterreich Justizministerin Claudia Bandion- berhhten Nachfrage wesentlich. nach bestimmten Ausbildungsf- bedeuten. Ortner. Mit Przisierungen gegen- Und an seiner grundlegenden Kri- Bestrebungen nach chern mit tik hlt der Jurist fest. Ich Medizinstudienpltzen in ber dem ursprnglichen Entwurfdem Erlass spezifischer, mehr halte
Politiker uneinsichtig
Und was sagen sterreichische Politiker? Wissenschaftsministerin Beatrix Karl verkndet vollmundig, die bestehenden (rechtswidrigen) Zugangsbeschrnkungen bis 2017 einfach verlngern zu wollen. Der Minister fr europische und internationale Angelegenheiten Michael Spindelegger will die (rechtswidrige) Quotenregelung unbefristet verlngern. Bereits 2005 hat der EuGH sterreich die Mglichkeit geboten, eine allfllig gerechtfertigte Diskriminierung nachzuweisen (etwa durch eine Quantifizierung der Beeintrchtigung fr den sterreichischen Gesundheitssektor durch die Tatsache, dass auslndische Medizinstudenten nach Beendigung ihres Studiums sterreich wieder verlassen und somit als rzte in sterreich fehlen). sterreich war dazu nicht fhig oder willens. Man gab an, ber keine Zahlen zu verfgen und dass die sterreichische Regelung zum Hochschulzugang ohnehin im Wesentlichen vorbeugenden Cha-
Terroristenausbildung im Visier des Strafrechts
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Pflicht zum Verbleib im Land?
Die Quotenlsung knnte durchaus EU-konform sein, blo msste sterreich endlich die Zahlen auf den Tisch legen und Farbe bekennen: Wo ist der Nachteil fr das sterreichische Gesundheitswe-
sen? Auch hat es ster tunlichst unterlassen, in der EU zu suchen etwa aus welchen Gr immer dem aktuelle gegen Belgien nicht Eine Koppelung an Stu ren wird von Experte als mglich angesehe der Generalanwalt im aus 2005 hat spter dass es rechtskonform lndische Studente Abschluss ihres Studiu (zeitlich befristeten) keit in sterreich zu v Aber auch diesen Weg reich offensichtlich n Es scheint fast, als Kreise in der Regieru ungelsten Situation g unzufrieden sind, gibt durch eine Art Quasi-L fr weitere Beschrnk Universittszugangs. Mgliche EU-konf sungsanstze sind som ren auf dem Tisch. D Urteil des EuGH gegen ffnet weitere Mglich terreich kann oder w nicht die ausgestreckt greifen. Der Autor ist Experte f recht und Internation legenheiten; er bt div und Beratungsttigk
AUF EINEN BLICK

Q Das
Delikt der Verhetzung wird ausgeweitet. Bisher durfte man ffentlich nicht gegen eine Religionsgemeinschaft hetzen oder gegen eine Gruppe von Menschen, die sich durch ihre Rasse, das Volk, den Volksstamm oder ihren Staat definiert.
Lsst Sie mit Ihren Rechtsfragen nicht allein!

Mageschneiderte Rubriken fr die Heim- und Pegepraxis: Haftung, Kosten & Qualitt Q Seit Juli 2008 gilt im Asyl GuKG, Arbeitsrecht & Anstaltenrecht verfahren ein neuer Instanzenzug. Pegegeld & Sozialrecht Heimaufenthalt & Unterbringung Gegen Bescheide des Bundesasyl-
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Jetzt ist der Verfahrensrucksack am Asylgerichtshof bereits zur Hlfte abgebaut.

Harald Perl, Prsident des Asylgerichtshofs
Der Asylgerichtshof wird an seiner Entscheidungszahl gemessen. Das halte ich fr problematisch.
Gerhard Muzak, Professor fr Verwaltungsrecht, Wien
Beim Verfassungsgerichtshof kann man so gut wie gar nicht mit Verfahrensfehlern kommen.
Nadja Lorenz, Rechtsanwltin in Wien
Die Rechtsprechung ist nicht einheitlich. Bei gleich gelagerten Fllen wird anders entschieden.
Karin Keil, Referat fr Flchtlingsfragen der Caritas
Der Rucksack wurde vom VwGH auf VfGH bertragen. Was das fr einen Sinn machen soll, wei ich nicht.
Kurt Heller, Exrichter am Verfassungsgerichtshof
senats (einer Behrde des Innenministeriums) beruft man nun beim Asylgerichtshof. Dessen Urteile kann man nicht mehr beim Verwaltungsgerichtshof anfechten. Nur der Weg zum Verfassungsgerichtshof blieb offen. Dieser kann nur bei sehr schweren, in die Verfassungssphre reichenden Fehlern Urteile des Asylgerichts aufheben. Der neue Instanzenzug hat das Asylverfahren beschleunigt. Kritiker frchten aber eine Verkrzung im Rechtsschutz.
Q Vertreter von Gruppierungen, die sich durch ihre Hautfarbe, die Sprache, die Weltanschauung, die Herkunft, ihr Geschlecht, eine Behinderung, das Alter oder die sexuelle Ausrichtung definieren, sind knftig strafrechtlich geschtzt. Bestraft wird man bereits, wenn man ffentlich eine solche Gruppe in einer die Menschenwrde verletzenden Weise beschimpft oder verchtlich zu machen sucht. Die Strafdrohung betrgt bis zu zwei Jahre Haft.
will die Ministerin sicherstellen, die Regelung nach wie vor fr berzogen, meint Funk. dass es die Richtigen trifft. Das Problem seien aber nicht I So wird knftig bereits die Ausbildung fr terroristische Zwecke die neuen Straftatbestnde an mit bis zu zehn Jahren Haft be- sich, sondern eine Definition, die droht sein. Schler mssen mit bereits jetzt im Gesetz steht und In der die auch auf diewerden Zugangsbeschrnkungen eingefhrt, die WU scheiterte mit ihrem Antrag. Publizistik neuen Tatbestnbis zu fnf Jahren rechnen. Kritiker monierten, dass selbst Englisch- de durchschlagen werde. Paragraf sungsbeschrnkungen aber die ihrem Wunsch, im Architektur- (VP) schickt jedoch ihren vollVON 278 AICHINGER kurse strafbar sein knnten, wenn PHILIPP (3) StGB legt fest, wer als Mitstudium erstmals Beschrnkungen stndigen Entwurf in BegutachPolitik. eine Person sie belegt, um spter glied einer kriminellen Vereinitung, der Hrden bei allen UniDas fhrte in den letzten Wo- einzufhren. Terrorist zu werden. DerWIEN. Notfallparagraf nennt sich neue Ent- gung gilt. Dieser Mitgliedsbegriff Genehmigt werden sollen hin- versitten vorsieht, die dies bei das Zauberwort, mit weit ster- chen zu in wurf aus dem Justizministerium ist sehr dem gezogen und gilt mehrfachen Diskussionen die terroprzisiert daher, dass reich einen zu groen Ansturm frzwischen SP und VP. Die gegen Eingangshrden in der Pu- ihr beantragt haben. Die endglman nur weiterer Folge auch strafbar ist, wenn derdeutscher Studenten Vereinigung. Sozialdemokraten wehrten sich blizistik, die von den Hochschulen tige Entscheidung soll im Mai im Lernstoff ristische verhindern will. terspezifisch zur Begehung einer124b Abs 6 des Universitts- gegen weitere Zugangsbeschrn- in Wien, Salzburg und Klagenfurt Ministerrat fallen. gesetzes Wie schnell ist man kungen. roristischen Straftat geeignet ist. sieht vor, dass die Univer- Mitglied? Der Antrag der Wiener gefordert wurden. Hier war auch Freie Hand bei Medizinstudium sitten Antrge auf Zulassungs- Wirtschaftsuniversitt (WU) auf die SP Zugangsbeschrnkungen I Auch wird es verboten, in Me- Demnach ist ein Mitglied auch jebeschrnkungen stellen knnen. Zulassungsbeschrnkungen im Stu- nicht abgeneigt. Dem Vernehmen Freie Hand haben die Unis hingedien oder im Internet Anleitungen mand, der sich nur auf andere Erlaubt ist Weise in Studien, dium der Wirtschafts- und Sozial- nach machte vor allem die Salz- gen in den Fchern Medizin, Psyzur Begehung einer terroristischen dies bei allendem Wissen beteiligt, fr die in Deutschlanddadurch die Vereinigung Straftat zu geben. Strafdrohung: dass er ein Nume- wissenschaften wurde daher bei burger SP-Landeshauptfrau Gabi chologie, Tier- und Zahnmedizin. bis zu zwei Jahren Haft. rus clausus gilt. Derderen strafbare Handlungen oder Antrag ist von einem Gipfel der Regierungspar- Burgstaller Druck, weil es in der In diesen Studien darf das Rektoall jenen Universitten, an denen teien am I Fr Diskussionen sorgt eine frdert. Und unter diese General- Grndonnerstag abge- nahe Deutschland gelegenen rat gem 124b Abs 1 Universidas betreffende Studium angebo- lehnt. Ebenso scheiterten die Uni Mozartstadt Kapazittsprobleme ttsgesetz Auswahlverfahren festneue Norm, die nicht nur die Auf- klausel knne man sehr schnell ten wird, zu indem Innsbruck forderung, sondern auch das Gut-gemeinsametwa stellen. man einer und die Technischen in der Publizistik gibt. Wissen- legen. Von diesem Recht machen fallen, muss die Zulas- Universitten Graz und Wien mit schaftsministerin Beatrix Karl die Universitten auch Gebrauch. heien terroristischer Genehmigen Gruppierung einen Computer zur Taten mit bis zu zwei Jahren Haft bedroht. Whrend nmlich die Verhetzung im neuen Entwurf nicht mehr unter den Begriff einer terroristischen Straftat fllt, ist dies beim Gutheien von terroristischen Taten nach wie vor der Fall. Strafrechtlerin Ingeborg Zerbes hlt es aber fr problematisch, dass ein Delikt, das man durch Meinungsuerung begeht, als terroristische Tat eingeordnet wird. Verfgung stellt, meint Funk. Das Justizministerium beschwichtigt: Es msse eine gewisse Intensitt vorliegen, damit jemand als Mitglied einer kriminellen oder einer terroristischen Vereinigung gilt. berdies msse die betreffende Person wissen, dass die Vereinigung kriminelle Plne schmiedet. Der bloe Sympathisant ist nie Mitglied einer terroristischen Vereinigung, betont Bandion-Ortner.
AUF EINEN BLIC

Q Der
Europische Ge urteilt morgen ber die Zugangsbeschrnkunge Ansturm franzsischer S verhindern sollen. Zu kl ob man Studienpltze a Wohnsitz- oder Aufenth erfordernisse knpfen d sterreich wurde bereit Europischen Gerichtsh Kurz darauf wurde die Q regelung eingefhrt, die Medizin 75 Prozent der pltze fr sterreicher r Auch dies ist EU-rechtli problematisch. Die Kom hat bisher aber kein Ve gegen sterreich einge
diepresse.com/rechtspanorama
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