Exchange of Information for Tax Purposes

S. 7Editor’s Preface

The present volume comprises the Master’s theses of the full-time students attending the 2012/13 class of the postgraduate LL.M. program “International Tax Law” at WU (Vienna University of Economics and Business).

Over the past years, this year’s general topic, “Exchange of Information for Tax Purposes”, has been a crucial issue in practice as well as in academia. In today’s globalized world taxpayers have become increasingly mobile and spread their activities and investments across states. The powers of national tax authorities are, however, restricted to the territorial limits of their country. Thus, transnational mutual assistance through an effective worldwide system of information exchange for tax purposes is most important. International cooperation in tax matters is, in the context of the current economic crisis, fostered by governments’ need to optimize tax assessment and collection as well as to fight aggressive tax planning, tax evasion and tax fraud. However, practice shows that international exchange of information for tax purposes, which can form the basis for the recovery of taxes in cross-border scenarios, meets various difficulties and requires const...