1 - Preface [Seite 5]
2 - List of Authors [Seite 7]
3 - List of Abbreviations [Seite 15]
4 - Recent developments in international VAT/GST tax policy [Seite Recent developments in international VAT/GST tax policy]
- 21 [Seite 21]
5 - Recent Developments in International Direct Tax Policy [Seite Recent Developments in International Direct Tax Policy]
- 48 [Seite 48]
6 - VAT and direct tax policy on reduced tax rates [Seite VAT and direct tax policy on reduced tax rates]
- 77 [Seite 77]
7 - VAT and direct tax policy on exemptions [Seite 107]
8 - Tax Compliance in VAT/GST and Direct Taxation [Seite Tax Compliance in VAT/GST and Direct Taxation]
- 129 [Seite 129]
9 - The principle of neutrality: VAT and direct taxes [Seite The principle of neutrality: VAT and direct taxes]
- 155 [Seite 155]
10 - Taxable persons in direct taxation and VAT [Seite 183]
11 - Nexus of taxation in VAT and direct taxes [Seite 212]
12 - Fixed and Permanent Establishments in VAT/GST and direct taxation [Seite Fixed and Permanent Establishments in VAT/GST and direct taxation]
- 234 [Seite 234]
13 - Group Taxation in VAT/GST and Direct Taxes [Seite 257]
14 - Transfer Pricing Implications for VAT/GST [Seite 295]
15 - The economic relevance of current VAT law for share deals - an analysis of ECJ case law [Seite The economic relevance of current VAT law for share deals - an analysis of ECJ case law]
- 326 [Seite 326]
16 - The taxation of electronic services in VAT/GST and direct taxes [Seite The taxation of electronic services in VAT/GST and direct taxes]
- 358 [Seite 358]
17 - Tax Abuse: comparison of indirect and direct taxation [Seite Tax Abuse: comparison of indirect and direct taxation]
- 393 [Seite 393]
18 - Financial and insurance services in VAT/GST and direct taxation [Seite Financial and insurance services in VAT/GST and direct taxation]
- 422 [Seite 422]
19 - Sale of Immovable Property: Development Looks for an Exemption or there and back again [Seite Sale of Immovable Property: Development Looks for an Exemption or there and back again]
- 444 [Seite 444]
20 - Public Bodies in direct taxation and VAT/GST [Seite 474]
21 - Charities in direct taxation and VAT/GST [Seite 501]
22 - Entertainers and Sportspersons in Direct Taxation and VAT [Seite Entertainers and Sportspersons in Direct Taxation and VAT]
- 532 [Seite 532]
23 - Impact of Art. 24 OECD Model Convention on VAT/GST [Seite Impact of Art. 24 OECD Model Convention on VAT/GST]
- 566 [Seite 566]
24 - Impact of Arts. 26 and 27 OECD Model Convention on VAT/GST [Seite Impact of Arts. 26 and 27 OECD Model Convention on VAT/GST]
- 593 [Seite 593]
25 - A Model Convention for VAT/GST [Seite 620]
26 - The share deal as a transfer of a going concern (TOGC) in VAT [Seite The share deal as a transfer of a going concern (TOGC) in VAT]
- 642 [Seite 642]
27 - Advance Rulings in Direct Tax Law and VAT/GST [Seite Advance Rulings in Direct Tax Law and VAT/GST]
- 667 [Seite 667]
28 - State aid issues in VAT and direct taxation [Seite 687]
29 - WTO law: VAT/GST vs. direct taxes [Seite 716]
VIIList of Authors
Andreas Benkitsch
received his engineering degree from the University of Leoben in 1995 with summa cum laude (Rektor Platzer Ring). In 1998, while working full time for a semiconductor fab, he completed his Ph.D. in Semiconductor Physics summa cum laude. He holds an MBA from the Haas School of Business (UC Berkeley, MBA00) and the London School of Business (LBS, IEP99). From 2001 to 2005 he worked as an investment executive for 3i plc, an international listed Private Equity Fund (FTSE100). He is a CFA® charterholder and currently serves as an external CFO to portfolio companies of international PE-Funds.
Christina Derer
graduated from the Technische Universität München (TUM) in Germany in 2011, receiving a Diploma degree in economics (Technology and Management TUM-BWL). Since 2008, she has been working mainly in the fields of Controlling, Accounting and Taxes in multinational enterprises in Germany and abroad (China, Spain). Currently she is part of the Transfer Pricing team of a multinational enterprise with its headquarters in Munich.
Slawomir Forenc
Slawomir Forenc graduated with honours from Maria Curie - Sklodowska University in Poland where after studies in law and history he obtained a Master in Law Degree in 2002. After the state examinations and two years' work experience in tax consultancy, he received his professional qualification as tax advisor. Subsequently, he passed the bar exams with honours and joined the National Chamber of Legal Advisors in Poland. He has worked for several medium-sized law firms dealing with tax litigation and providing legal counsel in all major areas of tax law. He is presently partner at S. Forenc & M. Serewa Sp. p. Law Firm where he is responsible for tax litigation, international tax planning, VAT and direct tax consultancy.
Daniele Frescurato
Daniele Frescurato graduated in international economics at the University of Verona (Italy) in 2007 and is an Italian Chartered Accountant and Certified Auditor registered at the local association of Vicenza (Italy). After starting his professional career in the tax and legal practice of two international accounting firms, first in Luxembourg and then in Italy, he has been working as an international tax speVIIIcialist in the International Tax Affairs department at Assicurazioni Generali SpA in Trieste (Italy) since 2012.
Simona Genini
Simona Genini was born in Locarno, Switzerland, in 1971. After having completed university with a law degree, she passed the bar exam in 1999. Since 1998 she has been working for the Ticino Cantonal Government in several positions within the Finance Department. Currently, she is head of the Law Department at the Cantonal Tax Administration in Bellinzona. She gives lectures at the SUPSI (Scuola Universitaria Professionale della Svizzera Italiana) and at the CSB (Centro di Studi Bancari).
Mária Janusková
Mária Janusková obtained a degree in economics at the University of Economics with a specialization in tax and tax consulting in the Slovak Republic. She has been working as a tax consultant since 2001 and received a licence as tax advisor in 2008. From 2001 to 2005 she worked for BMB Leitner in Bratislava. Since 2005 she is a tax advisor and manager at TPA Horwath in Bratislava.
Sandra Kartal
Sandra Kartal holds a degree as a Swiss Certified Tax Expert and works as a Senior Tax Manager in the tax and legal department of the Swiss company KENDRIS Ltd. in Zurich. In 2005, she received a Bachelor degree in Business Administration from the Zurich University of Applied Sciences with focus on Finance and Accounting. After her studies she started her career in the corporate tax department of Deloitte and gained further experience as a Tax Inspector at the Cantonal Tax Authority of Zurich. At her current position she is mainly assisting companies with the Swiss and international aspects in cross-border tax planning.
Alexandra Kaspar
Alexandra Kaspar graduated from the University of Applied Sciences for Business Consultancy in Wiener Neustadt, Austria, in 2003 and has been working as a tax consultant in Vienna since then. She obtained the professional qualifications as Austrian Certified Tax Advisor in 2007 and as Austrian Certified Public Auditor in 2010. Currently, she is working as a tax advisor at RSM Austria, Vienna, with a special focus on international tax issues, corporate taxation and VAT.
Karol Kassovic
Karol Kassovic received a degree in accounting at the University of Economics in the Slovak Republic. After graduation he worked in various accounting and corporate controlling positions. In the 2004 he received the CFA charter. Currently he is accounting and tax manager at an oil refining company.
IXThomas Katzmayr
Thomas Katzmayr was born in Linz (Austria) in 1983. He received two degrees in business administration at the Vienna University of Economics and Business. He has been working as a tax consultant since 2006. Currently he is a tax advisor at Moore Stephens Austria.
Michael Kern
Michael Kern received a degree in Finance, Accounting and Taxation at the University of Applied Sciences for Communication and Business Management in Vienna. He has been working as a tax consultant since 2009. Since 2013 he is a partner at the tax consulting firm Steuer & Service Steuerberatungs GmbH in Vienna.
Marco Mosconi
Marco Mosconi was born in Ancona (Italy) in 1968 and graduated summa cum laude in Economics and Management from Bocconi University (Milan) in 1993. He successfully passed the State Exam as "Dottore Commercialista e Revisore Contabile" ( i.e. Chartered Accountant / CPA and Certified Auditor) in 1993. He has been teaching Financial Accounting at Bocconi University from 1993 to 2013. He is a Tax Advisor and Auditor at Mosconi & Associates in Monza and Milan (Italy), member of MonzaLegal team. He is Professor at SDA Bocconi School of Management where he has been teaching since 1994.
Adrian Muster
Adrian is a tax practitioner in Switzerland (awr cross border projects ltd), where he consults for businesses on ownership structures. Many of his clients are public entities. He was a founding partner of the partnership 'awr ltd' with five partners. Previously, Adrian headed the tax department of a 'Big Four' audit firm. Adrian completed his studies at Berne University. He is an attorney at law, registered with the attorneys' registry, and a Swiss Certified Tax Consultant. His doctoral dissertation was published as a commentary on inheritance taxes (Erbschafts- und Schenkungssteuerrecht, Muri bei Bern, Cosmos Verlag).
Florian Otto
Florian Otto studied Law at University of Erlangen and International Business at Reutlingen School of International Business (Germany). After graduation, he joined the Capital Market department of a major German bank, servicing corporate and institutional clients on currency and interest rate management and on structured investment solutions. Since 2006, he has been working for UBS Zurich in different positions in the Investment Bank and the Wealth Management Division. He is currently director of Tax Regulatory Projects, focusing on topics like FATCA, Exchange of Information and cross-border investment taxation.
XRadovan Pistek
Radovan Pistek received a degree in law at the University of Trnava in the Slovak Republic. From 2004 to 2009, he worked as a tax consultant at Ernst & Young and at Deloitte in Bratislava. Currently, he is legal counsel at the law office Law&Trust, providing legal and tax counsel in connection with his position of Deputy General Counsel at HB Reavis Group.
Lucie Rytírová
Lucie graduated from the University of Economics in Prague (VSE) with a degree in Business Law. She is a Tax Manager at Deloitte and focuses on issues related to the taxation of individuals, including social security and health insurance, remuneration, employee structures and international employment. In 2012 - 2013, she worked at the Ministry of Finance of the Czech Republic, where she prepared a reform of the personal income tax, social security and health insurance collection system. As an active member of the Chamber of Tax Advisors of the Czech Republic, Lucie contributes to the drafting of new legislation and the preparation of official interpretations not only in the personal income tax area, but also in international taxation and social security legislation. She also publishes, lectures and participates in the EU Commission's Expert Group on removing tax problems facing individuals who are active across borders within the EU.
Balazs Sagh
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