Access to Treaty Benefits (eBook)
496 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1161-2 (ISBN)
A rigorous analysis of various aspects related to treaty access
Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse.
The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
IXList of Authors
Tomás Álvarez Palacios
Tomás Álvarez Palacios was born in Santiago de Chile in 1986. In 2011, he completed his B.A. in Law at the Pontificia Universidad Católica de Chile. He also holds an LL.M. in Tax Law from the Universidad Adolfo Ibáñez, Chile (2015). From 2012 to 2015 he worked at two law offices in Santiago de Chile: Boffil Mir & Álvarez Jana Attorneys and Porzio, Ríos, García Attorneys. After that, he joined Mazars Chile as a Tax Attorney and was promoted to Tax & Legal Manager in 2017. He joined KPMG Chile in 2018 as a Supervisor Attorney in the International Corporate Tax Department.
Eva Bernichon
Eva Bernichon graduated in 2020 with a Master‘s degree in Corporate Taxation and a Magistère in Business Law, Taxation and Accounting from the University of Aix-Marseille in France. After one year’s practice experience as a tax assistant in the financial department of BlaBlaCar, she is now enrolled at the Versailles Law School in France in order to become a tax lawyer.
Gonzalo Breña Labarrere
Gonzalo Breña Labarrere received a BA in law at the Universidad Iberoamericana, campus Mexico City. He has worked as a Mexican tax lawyer providing legal counsel in connection with taxation and legal assistance in Mexican and international tax law.
Tomas Delfiner
Tomas Delfiner obtained a Bachelor of Arts (BA) in Business Administration degree from the University of Buenos Aires and recently successfully completed his Master of Laws (LL.M.) in International Tax Law at the Vienna University of Economics and Business (Wirtschaftsuniversität Wien). He has extensive working experience at large international consulting companies in the tax and financial planning area.
Svjetlana Dukić
Svjetlana Dukić received a bachelor’s degree at Vienna University of Economics and Business (Wirtschaftsuniversität Wien) and a master’s degree at University of applied Science BFI Vienna-programme “European Economy and Business Management”. She has been working as a tax consultant since 2018 providing tax counsel in connection to Global Mobility at PricewaterhouseCoopers in Vienna. In the future, however, she would like to engage her knowledge and experience in field of African tax policy.
XRozina Filipszki-Karazeybek
Rozina Filipszki-Karazeybek was born in Budapest in 1990 and studied law at the University of Vienna (Mag. iur.). She graduated in 2018, specialized in EU Law and started her career as a trainee in the VAT Department at Ernst & Young Vienna. After completing the traineeship, she proceeded to judicial practice and worked for two years as tax consultant in internationally operating tax firms. From July 2021 she will join a Vienna based tax firm as tax specialist and also plans to take the Austrian tax advisory exam.
Diego Fischer
Diego Fischer is a qualified lawyer in Brazil. He graduated in law from Pontifícia Universidade Católica de São Paulo (PUC-SP) and has an LL.M degree in tax laws from Fundação Getúlio Vargas (FGV – GVLAW). Since 2016, he has worked as an associate lawyer in Brazil advising multinational companies on legal, corporate, and international tax matters. Currently, he is an associate lawyer working at Vella Pugliese Buosi e Guidoni Advogados.
Caroline Guimarães
Caroline Guimarães graduated in law from the University of São Paulo (USP) in 2017. In 2018 and 2019, she did postgraduate courses at the Instituto Brasileiro de Direito Tributário (IBDT) in national and international tax Law, respectively. She has been a member of the Brazilian Bar and has worked as a tax lawyer since 2018.
Laura Jiménez Martínez
Laura Jiménez was born in Mexico in 1990. In 2014, she graduated from Universidad Panamericana in Mexico City with a B.A. degree in law and a speciality in Constitutional Law. From 2013 to 2020, she has worked as a tax lawyer in Mexico City, focusing on litigation and tax advisory. She began her career at one of the most prestigious law firms in Mexico where she worked for more than six years in the areas of domestic and international tax law. She then continued her practice as a senior associate at Ernst & Young Mexico. During the years of her practice, Laura has collaborated in various publications on Mexican and international tax developments.
Jeff Konings
Jeff Konings received a master’s degree in law with honours at the Catholic University of Leuven located in Belgium. This year, he will start working as a junior associate at Tiberghien Law firm located in Brussels.
Aleksandra Krasnobaeva
Aleksandra Krasnobaeva received a master’s degree in economics (International Tax Planning) at the Financial University under the Government of the Russian XIFederation. She has more than five years of experience in cross-border business tax structuring. Currently, she is a YIN Representative in Russia and senior consultant at EY Russia. After graduation from the WU, she will continue working on her PhD thesis focusing on the aspects of corporate income taxation in the digital economy.
Shuangshuang Lu
Shuangshuang Lu received a degree in International Taxation and Law at Rhine Waal University of Applied Sciences in Germany. She worked as a trainee for China’s tax authorities, was a finance intern at Robert Bosch GmbH in Stuttgart, Germany, and an accounting executive at Guangxi Yin Kai Sugar Supply and Marketing co. LTD in Nanning, China. She is now a student candidate of China’s CPA.
Fabrizio Pascucci
Fabrizio Pascucci received a degree in law at LUISS Guido Carli University in Rome and a degree in economics and business administration at University of Roma 3. He is a qualified tax lawyer and has been working as tax advisor since 2014 in leading tax law firms. He holds lectures in international taxation and EU taxation.
Alberto Piscini
Alberto Piscini received a master degree in law at the University of Bologna in Italy. From 2018 to 2020, he worked as an international tax consultant in the International Tax and Transaction Services at EY in Rome.
Emilia Rebetez
Emilia Rebetez completed her Bachelor’s and Master’s Degrees in Law at the Universities of Geneva, Neuchâtel, Fribourg, and Glasgow. She was admitted to the Swiss Bar as an Attorney-at-Law in 2016 and obtained the title of Swiss Certified Tax Expert in 2019. Prior to enrolling for the LL.M. in International Tax Law 2020/2021 Program at the Vienna University of Economics and Business, she was a Senior Associate in the Tax Department of Lenz and Staehelin, where she practiced for seven years advising individuals, corporations, public and private institutions, charities, as well as Swiss and foreign regulated entities in all areas of domestic and international tax law. She has a keen interest in the education field and has taught classes at the Universities of Geneva, Lausanne and Neuchâtel. As per September 2021, she will be joining Walder Wyss in a position of Managing Associate.
Anthony Roustan
Anthony Roustan completed his Master Degree in Corporate Taxation at Aix-Marseille University (France) in June 2020. He is currently a student at the Bar School of Versailles in order to become a tax lawyer. He has worked in several law firms during his studies, including one year at PricewaterhouseCoopers in Marseille.
XIIVivien Tomio-Onghay
Vivien Tomio-Onghay has been educated in arts, business management, tax law, and accounting law at different universities in various countries, namely, Italy, the United Kingdom, Australia, and Austria. Currently, she is pursuing an honours degree in law and a Master of Law degree in European and International Business Law. Vivien has worked in the public and private sectors in arts, business management, financial services, and tax law in different countries on four different continents. She has also worked independently on various projects across the industry and the non-profit sector. Following this degree program, she will continue her education, focusing on international law. Vivien will work in the international tax law department at a multinational consulting company.
Anne Maria Weiske
Anne Maria Weiske is a fully qualified German lawyer. She completed her First State Examination in Munich and Leipzig with a specialization in tax law in 2017, and her Second State Examination in Frankfurt and London with a focus on business law in 2020. During her legal clerkship, she was part of the Private Funds Team at POELLATH and engaged in advising clients on legal and tax related aspects of alternative investments. After completing the LL.M. Program in International Tax...
Erscheint lt. Verlag | 21.9.2021 |
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Sprache | englisch |
Themenwelt | Recht / Steuern |
ISBN-10 | 3-7094-1161-0 / 3709411610 |
ISBN-13 | 978-3-7094-1161-2 / 9783709411612 |
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