S. 5Series Editor’s Preface

The postgraduate program in International Tax Law at the Vienna University of Economics and Business Administration is available either as a one-year full-time or a two-year part-time program. Students attend not only a vast number of courses, for which they prepare papers and case studies, and sit numerous examinations, they also write their Master’s theses. These theses are a prerequisite for the academic degree “Master of Laws (LL. M.)”.

The program follows a scheme under which the Master’s theses of one particular program all discuss various aspects of the same general topic. The general topic of the 1999/2000 full-time program was “Electronic commerce and taxation”; that of the 1999/2001 part-time program “Transfer pricing”. We had selected “Partnerships in International Tax Law” as topic of the 2000/2001 full-time program, “Exemption and credit methods in tax treaties” for the 2001/2002 full-time program, „Permanent Establishments in International Tax Law“; for the 2002/2003 full-time program, and “Non-discrimination provisions in tax treaties” for the 2001/2003 part-time program. The full-time program 2003/2004 had the general topic “Triangular Cases” and the part-time program 2003/2005 dealt with “Source versus Residence in International Tax Law” The respective Master’s theses were published in edited volumes. The general topic for the 2004/2005 fulltime program was “Tax Treaty Policy and Development” and the one for 2005/2006 full-time program was “The Relevance of WTO Law for Tax Matters”.

The general of this part-time course were “Artistes and Sportsmen”. A common subject does not only encourage students to discuss their theses with each other, but also permits looking after the students in accompanying courses. Prof. Daniel Sandler introduced the students to the subject matter at the beginning of the year. Dr. Walter Loukota and Dr. Markus Stefaner held seminars in which the structure of the papers and the intermediary results were analyzed critically. It was with great commitment that they supported the students who prepared their Master’s theses, and their numerous suggestions helped improve the quality of the Master’s theses and, as a consequence, the quality of the present volume. In both of my functions as the scientific director of the postgraduate program and the editor of this series I wish to express my gratitude to my two colleagues.

I am grateful also to the students themselves. They pursued the program with great enthusiasm. This postgraduate program did not only give them the opportunity to talk to academics and scientifically qualified interns from all over the world and to acquire a wealth of knowledge, they also learnt how to tackle and solve complex issues using a structured approach. The Master’s theses now available bear witness to this. I hope that the results of these papers will both influence the scientific discussion and be of use to tax practitioners.

Michael LangS. 6