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Double Non-Taxation - FWF

About the Project:

The increasing importance of cross-border business activities is accompanied by a rising complexity of international tax planning. Inconsistencies in domestic rules are relentlessly being exploited by multinationals through sophisticated arrangements in order to reduce the global tax burden. The existing tools of tax authorities do not provide a comprehensive response to cases of double non-taxation resulting from such highly complex transactions. The OECD and the European Commission are anxious to provide concrete solutions to realign international tax standards. These initiatives are of paramount importance for the future of international tax law. However, there is a substantial lack of fundamental research. It is the aim of this research project to fill this gap and to offer a comprehensive analysis of the possibilities to avoid double non-taxation.