Limiting Base Erosion

S. VII Editors’ Preface

The present volume comprises the Master’s theses of the part-time students attending the 2015–17 class of the postgraduate LL.M. program “International Tax Law” at WU (Vienna University of Economics and Business). The general topic this year was “Limiting Base Erosion”, which has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis of the issues related to base erosion proves to be of utmost importance in order to provide practical guidance to the Member countries during the process of implementation.

For the purposes of this book, it was decided to focus on few selected areas of th...