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 article is a reply to Martin Wichmann's reply from a German perspective to John F. Avery Jones's article 'Why Can't the English ... ?', both published in the Bulletin for International Taxation of the International Bureau of Fiscal Documentation (IBFD), 2019 (Volume 73), No. 6/7. It argues...

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...