The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

This book chapter suggests that nineteenth-century tax treaties and federal laws of German speaking European countries that concerned double taxation established the basis from which tax treaties and model conventions developed in the following centuries. The content of these German tax treaties...

Tax comparatists tend to bemoan the grim status of their chosen field. Complaints are aimed both at the scarcity of decent comparative legal tax scholarship, and at the lack of a theoretical foundation for the study of comparative tax law. The purpose of this Article is to portray a more...