Non-Discrimination in European and Tax Treaty Law

S. VIIEditors’ Preface

The present volume comprises the Master’s theses of the full-time students attending the 2014/15 class of the postgraduate LL.M. program “International Tax Law” at WU (Vienna University of Economics and Business). The general topic this year was “Non-Discrimination”, which plays an important, if not crucial, role in many areas of law, such as constitutional law, human rights law, world trade law, EU law and tax treaty law. Both direct and indirect taxation are affected by the various types of non-discrimination provisions. From a practical point of view, the non-discrimination provisions within the EU legal framework and the non-discrimination concept under Article 24 of the OECD Model are important examples in this respect.

The contributions in this book deal, on the one hand, with questions that can be described as evergreens of non-discrimination law, since they have been debated for a long time. On the other hand, they deal with current challenges that have emerged only recently, particularly because of current developments at the OECD level, notably the BEPS project. Although the provisions are different in wording and context, the same issues can often be analy...