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Die legistische Umsetzung des MLI in Österreich
The Legal Implementation of the MLI in Austria
Claus Staringer expressed great interest in the recent developments in international tax law concerning BEPS on various occasions. He evaluated these developments from a critical point of view, thereby expressing serious concerns whenever such developments led into a direction which might end up in unintended consequences. One of the most radical and challenging developments in international tax law is certainly the implementation of the MLI. In principle, Claus supported the way that Austria has just recently chosen to apply this treaty. However, there is still a long phase of implementation ahead of us on the basis of the current “covered tax agreements”. This article deals with the legal requirements as well as courtesy requirements which have to be respected for the sake of a clear and secure implementation of the MLI in Austria, in particular the preparation of consolidated versions of the bilateral tax treaties. I hope that Claus will also pay critical attention to this implementation procedure, and I would be more than happy if he continued to contribute to the academic discussion on this very important and challenging issue.
I. Ausgangslage
Österreich unterzeichnete das MLI a...