29.10.2024
When a tax treaty intends to eliminate double taxation and prevent tax evasion and avoidance, what happens if the only choice is between 1) preventing tax avoidance while leaving double taxation unresolved or 2) eliminating double taxation while allowing for tax avoidance? Which of these arguably conflicting objects and purposes should prevail in a particular case?
On October 24, Professor Kasper Dziurdz from Maastricht University gave a presentation on “conflicting objects and purposes in tax treaty law” during the tax@univie lecuture series at the University of Vienna.