The allocation of risk and of the income from risky investment and activities belongs to the central topics of international tax policy today. This fact is highlighted by the current BEPS initiative of G20 and OECD which casts doubt on the recognition of contractual risk allocation within...

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical view as to the existence of an “international tax regime”. Has the world changed since? On the one hand there is a strong move towards international tax coordination,...

International Taxation has a new GAAR: the “Principal Purpose Test” as laid down in Art.29(9) OECD Model Tax Convention (2017) and Art.7 Multilateral Instrument. While this new provision emphasises the relevance of the “purpose” of an arrangement or transaction, it does not refer...

International tax coordination has reached impressive results after the turn of the century. Multi-lateral agreements like the Common Reporting Standard or the BEPS Action Plan are clear signs of the willingness of a large number of states to cooperate in fiscal matters at a global scale....

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical view as to the existence of an "international tax regime". Has the world changed since then? On the one hand, there is a strong move towards international tax coordination,...