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.............................................................................................................................DescriptionConflicts of qualification arise because of diverging tax treaty application by the contracting states. The different allocation of taxing rights may lead to double taxation or double non-taxation which can be (un-) favourable for the taxpayers and tax administrations involved.The practical experience shows that there is a wide variety of possible conflicts of qualification. The master theses contained in this volume are dedicated to identifying conflicts of qualification and to develop solutions to the respective situations. Thereby, methodical issues are equally covered as the application of the distributive rules and the articles to avoid double taxation..............................................................................................................................ContentsSeries Editors' Preface.Editors' Preface List of AbbreviationsI - General Aspects of Conflicts of Qualification• Adalberto Ramos Huerta - Conflicts of Qualification and the Interpretation of Tax Treaty Law• Vijay Kumar Gupta - Conflicts of Qualification and Conflicts of Allocation of Income• Karin Leithner - Conflicts of Qualification and Timing IssuesII - Conflicts of Qualification and Tax Treaty Provisions• Filippo Federico Miotto - Conflicts of Qualification and Residence (Art. 1 and 4 OECD MC)• Nelly Karnaukhova - Conflicts of Qualification and Income Derived by Directors and Managers (Art. 15 and 16 OECD MC)• Kamila Prazuch - Conflicts of Qualification and Employer Issues (Art. 15 (2) (b) and (c) OECD MC)• Florian Beckermann - Conflicts of Qualification and Income Derived from International Shipping, Inland Waterways Transport and Aircraft Business (Art. 8 OECD MC)• Jana Faybik - Conflicts of Qualification and Capital Gains (Art 13 OECD MC)III - Conflicts of Qualification and Special Cross-border Situations• E. Elif Simsek - Conflicts of Qualification and Exit Taxation .• Alba Calleja Jimenez - Conflicts of Qualification Arising from Alternative Remuneration• Tamas Feher - Conflicts of Qualification and Hybrid Financial Instruments ..• Kamila Makhmudova - Conflicts of Qualification and Thin Capitalisation Rules .• Miryan Gharibo - Conflicts of Qualification in Connection with Partnerships • Marc Walter - Conflicts of Qualification and International Inheritance CasesIV - Possible Solutions for Resolving Conflicts of Qualification• Stephan Kienberger - Avoidance of Double (Non-) Taxation and Art. 23 A and B Paragraph 1 OECD MC .• Christian Ribera Caellas - Subject-to-tax Clauses in Tax Treaties• Patrick Weninger - The Role of Arbitration in Resolving Qualification Conflicts under Tax Treaties• Christian Korn - Avoidance of Double Non-taxation and Unilateral Provisions in Domestic LawList of AuthorsRegister .............................................................................................................................Author DetailsProf. Michael Lang is head of the Institute of Austrian and International Tax Law at the Vienna University of Economics and Business Administration.Dr. Eva Burgstaller is lecturer at the Institute of Austrian and International Tax Law at the Vienna University of Economics and Business Administration. She currently works at the tax department of Deloitte Vienna.Dr. Katharina Haslinger is lecturer at the Institute of Austrian and International Tax Law at the Vienna University of Economics and Business Administration. She currently works at the tax department of KPMG Vienna..............................................................................................................................
