A Decade of Case Law; Essays in honour of the 10th anniversary of the Leiden Adv LLM in International Tax Law

This book is in honour of the 10th Anniversary of the Leiden Adv LLM in International Tax Law. In today’s business environment conflicts related to cross-border tax matters are increasingly common. This book presents and analyses some of the most interesting and debated court decisions of the last decade. The issues analysed in this book include: • borderline between the definitions of royalties, know-how and services; • the definition of the term “employer” for treaty purposes; • the concept of permanent establishment in the context of a multinational group; • non-discrimination issues relating to domestic group consolidation; • the taxation of partnerships in cross-border situations; • the concept of place of effective management for treaty purposes; • the ever-debatable notion of “beneficial owner”; and • triangular situations.