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Full-Text Articles in International Trade Law
Dispute Resolution: The Mutual Agreement Procedure, Hugh Ault
Dispute Resolution: The Mutual Agreement Procedure, Hugh Ault
Hugh J. Ault
No abstract provided.
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Hugh J. Ault
This article is the revised text of a lecture held on May 2, 2013, at the Max Planck Institute for Tax Law and Public Finance. It focuses on the OECD's work on the definition of Permanent Establishment, the transfer pricing treatment of Intangibles and the recently announced project on base erosion and profit shifting ("BEPS"). After describing these positive law developments, Ault relates to more basic questions of how principles of international tax law, and particular the normative claims to taxing rights, are established.