The Oxford Handbook of International Tax Law

International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law.


Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law.

With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.

Section I: History and Scope of International Tax Law
1. The History of International Tax Law, Marilyne Sadowsky
2. From the “1920s Compromise” to the “2020s Compromise”, Roberto Bernales Soriano
3. Sources of Law and Legal Methods in International Tax Law, Rainer Prokisch
4. Jurisdictional Underpinnings of International Taxation, H. David Rosenbloom and Fadi Shaheen
5. International Tax Law and Customary International Law, Elizabeth Gil García
6. International Tax Law and its Influence on National Tax Systems, Craig Elliffe
7. International Tax Law and Personal Nexus, Michael Dirkis
8. International Tax Law and Low and Middle Income Countries, Akhilesh Ranjan
9. International Tax Law - Status Quo, Trends and Perspectives, Reuven Avi-Yonah
Section II: Relationship between International Tax Law and other Legal and Social Spheres
10. International Tax Law and Private International Law, Polina Kouraleva-Cazals
11. International Tax Law and Public International Law, Ch. HJI Panayi & K. Perrou
12. International Tax Law and Corporate Law, Marcos André Vinhas Catão and Verônica Melo de Souza
13. The Relation between International Tax Law and International Trade Law, Servaas van Thiel
14. International Tax Law and Economic Analysis of Law, Werner Haslehner
15. International Tax Law and Language, Florian Haase
16. Comparative Tax Law, Marco Barassi
Section III: Selected Issues on Tax Treaties and International Tax Law
17. Qualification Conflicts and Tax Treaties, Gianluigi Bizioli
18. Triangular Cases and Tax Treaties, Paolo Arginelli
19. The Future of Avoiding Double Taxation, Martin Berglund
20. Charities in Double Tax Conventions, Sigrid Hemels
21. Exchange of Information and Tax Treaties, Xavier Oberson
22. Beneficial Ownership and Tax Treaties, Dietmar Gosch and Nadia Altenburg
23. The Principal Purpose Test Under Tax Treaty Law, Robert J. Danon
24. Tax Treaties and Human Rights Law, Philip Baker QC
25. Taxation of International Partnerships, Ton Stevens
26. OECD Dispute Resolution, Marco Greggi
27. Regional Double Tax Treaty Models as Potential indicators of Regional Tax Treaty Policy, Craig West
28. Unilateralism, Bilateralism, and Multilateralism in International Tax Law, Miranda Stewart
29. Agents in International Tax Treaties, Sunita Jogarajan
Section IV: Legal Aspects of International Transfer Pricing
30. The Role of Article 9, Miguel Teixeira de Abreu
31. OECD Transfer Pricing Guidelines and International Tax Law, Yuri Matsubara and Clémence Garcia
32. Corresponding Adjustments, Matthias Hofacker
33. Transfer Pricing versus Formulary Apportionment, Georgios Matsos
34. Low Value-adding Services as a Safe Harbour under TP Regulations, Marcin Jamrozy
Section V: The Europeanization of International Taw Law
35. The Role of the ECJ in the Development of International Tax Law, Adrian Cloer
36. Tax Treaties and the EU Fundamental Freedoms, Marjaana Helminen
37. State Aid and International Taxation, Patricia Lampreave Márquez
38. International Tax Law and the EEA/EFTA, Patrick Knörzer
39. 21st Century Tax Challenges of the EU Candidate Countries, Savina Mihaylova-Goleminova
40. European Anti-Tax-Avoidance Regimes, Paloma Schwarz Martínez
41. Alternative Dispute Resolution in the EU, Isabelle Richelle
Section VI: Selected Issues of Cross-Border Indirect Taxation
42. Cross-Border VAT Aspects: The EU Approach and Evolving Trends, Roberto Scalia
43. Taxation of Imports, Thomas Bieber
44. “White Supplies” and Double Taxation in Cross-Border VAT Law, Heidi Friedrich-Vache
45. A Comparison Between EU VAT Law and the OECD International VAT/GST Guidelines, Eleonor Kristoffersson
Section VII: Recent International Tax Trends in Major Economies and Regions
46. The U.S. Perspective on International Tax Law, Kimberly A. Clausing
47. International Tax Reform in the Digitalized Economy: A Chinese Perspective, Bristar Mingxing CAO
48. The Indian Perspective on International Tax Law, Kuntal Dave
49. The Brazilian Perspective on International Tax Law: From Rogue Nation to Trend-setter?, Fernando Souza de Man
50. The German Perspective on International Tax Law, Gerhard Kraft
51. The Perspective of the EAC on International Tax Law, Afton Titus
52. The Japanese Perspective on International Tax Law, Masao Yoshimura
53. The Russian Perspective on International Tax Law, Elena Kilinkarova
Section VIII: Emerging Issues and the Future of International Tax Law
54. The Emerging Consensus on Value Creation: Theory and Practice, Allison Christians
55. The Allocation of Taxing Rights under Pillar One of the OECD Proposal, Aitor Navarro
56. International Effective Minimum Taxation - OECD/G20 Pillar Two (“GloBE”), Joachim Englisch
57. Challenges of the Emerging International Tax Consensus for Low- and Middle- Income Countries, Natalia Quiñones
58. Global Tax Governance, Irma Mosquera
59. The Future of Labor Taxation and the “Rise of the Robots”, Georg Kofler
60. Digitalization and the Future of VAT in the European Union, Michael Tumpel