Wolfgang Schoen

Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

Director

Marstallplatz 1

Munich, 80539

Germany

  • Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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Scholarly Papers (46)

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1.

Taxing Multinationals in Europe

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2012-11
Number of pages: 30 Posted: 06 Dec 2012
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 5,133 (3,029)
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multinational enterprises, European tax law, fundamental freedoms, international business taxation, corporate groups

2.

Ten Questions About Why and How to Tax the Digitalized Economy

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2017-11
Number of pages: 31 Posted: 21 Dec 2017
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 3,173 (6,825)
Citation 5

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International Tax Law, Digitalization, Digitized Economy, Corporate Tax, Tax Reform

3.

Debt and Equity: What's the Difference? A Comparative View

Max Planck Institute for Intellectual Property, Competition & Tax Law Research Paper No. 09-09
Number of pages: 99 Posted: 17 Sep 2009
Wolfgang Schoen, Tobias A. Beuchert, Astrid Roesener, Astrid Roesener, Andreas Gerten, Maximilian Haag, Sabine Heidenbauer, Sabine Heidenbauer, Carsten Hohmann, Daniel Kornack, Nadia Lagdali, Lukas Mueller, Christine Osterloh-Konrad, Carlo Pohlhausen, Carlo Pohlhausen, Philipp Redeker and Erik Röder
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law, Max Planck Institute for Tax Law and Public Finance, CMS Hasche SigleMax Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Vienna University, Institute for Austrian and International TaxlawMax Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, University of St. Gallen, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public FinanceHgCapital, Max Planck Institute for Tax Law and Public Finance and Max Planck Institute for Tax Law and Public Finance
Downloads 2,796 (8,255)

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Debt, equity, business tax, international tax, corporate law, corporate tax

4.

EU Tax Law: An Introduction

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2019-12
Number of pages: 107 Posted: 19 Aug 2019 Last Revised: 20 Aug 2019
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,644 (19,203)
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H2, H26, K33, K34

5.

Base Erosion and Profit Shifting: A Roadmap for Reform

Bulletin for International Taxation, Vol. 68, p. 275, 2014, Boston College Law School Legal Studies Research Paper No. 324
Number of pages: 6 Posted: 28 Jun 2014 Last Revised: 14 Jul 2014
Hugh J. Ault, Wolfgang Schoen and Stephen E. Shay
Boston College Law School, Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law and Boston College Law School
Downloads 1,641 (19,221)
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6.

International Tax Coordination for a Second-Best World (Part I)

World Tax Journal, Vol. 1, No. 1, pp. 67-114, September 2009
Number of pages: 48 Posted: 15 Apr 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,380 (25,004)

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International Tax Law, Corporate Taxation, Business Tax, Tax Competition, Profit Attribution, Allocation

7.

Residual Profit Allocation by Income

Oxford University Centre for Business Taxation Working Paper WP19/01, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2019-04, Oxford Legal Studies Research Paper No. 41/2019
Number of pages: 106 Posted: 22 Mar 2019 Last Revised: 27 Aug 2019
Michael P. Devereux, Alan J. Auerbach, Michael Keen, Paul Oosterhuis, Wolfgang Schoen and John Vella
Centre for Business Taxation, Oxford University, University of California, Berkeley - Department of Economics, International Monetary Fund (IMF) - Fiscal Affairs Department, Independent, Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law and Oxford University Centre for Business Taxation
Downloads 1,341 (26,046)
Citation 9

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International Tax, Tax Reform, Transfer Pricing, Digitalisation, OECD, Transfer Pricing, Intangibles, Tax Avoidance, Tax Competition, Tax Havens, Profit Shifting

8.

Transfer Pricing Issues of BEPS in the Light of EU Law

Reprinted from British Tax Review (BTR), 2015, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-9
Number of pages: 15 Posted: 09 Sep 2015
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,240 (29,276)
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International Tax Law, Tax Policy, European Law, BEPS

9.

Taxation and State Aid Law in the European Union

Common Market Law Review, Vol. 36, No. 4, pp. 911-936, 1999
Number of pages: 26 Posted: 10 Jun 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,223 (29,797)

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European Tax Law, Tax Competition, Tax Harmonization, Tax regulation, Subsidies, State aids

10.

Taxation and Democracy

Tax Law Review, Vol. 72, Forthcoming, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2018-13
Number of pages: 65 Posted: 22 Oct 2018
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,023 (38,519)

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Tax Law, Constitutional Law, Comparative Constitutional Law, Taxation, Democracy, Principles of Taxation, Citizenship, Tax Competition, Taxpayer Protection

11.

One Answer to Why and How to Tax the Digitalized Economy

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2019-10
Number of pages: 32 Posted: 27 Jun 2019
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 1,007 (39,466)
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International Taxation, Digital Economy, Tax Policy, Transfer Pricing, Taxing Rights, Digital Investment

12.

Debt and Equity in Domestic and International Tax Law — A Comparative Policy Analysis

Reprinted from British Tax Review (BTR), 2014, Nr. 2, p. 146 - 217. © Thomson Reuters (Professional) UK Limited and Contributors and Schön, Wolfgang /et.al., Working Paper of the Max Planck Institute for Tax Law and Public Finance 2014-09
Number of pages: 75 Posted: 08 Jul 2014 Last Revised: 14 Jul 2014
Wolfgang Schoen, Andreas Bakrozis, Johannes Becker, Tobias A. Beuchert, Martin Boer, Nadja Dwenger, Andreas Gerten, Maximilian Haag, Sabine Heidenbauer, Sabine Heidenbauer, Carsten Hohmann, Alexander Jehlin, Dr. Karin E.M. Kopp LL.M., Daniel Kornack, Nadia Lagdali, Christian Marquart, Lukas Mueller, Marta Castelon, Christine Osterloh-Konrad, Natalia Paxinou, Carlo Pohlhausen, Carlo Pohlhausen, Philipp Redeker, Erik Röder, Astrid Roesener and Astrid Roesener
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law, Max Planck Institute for Tax Law and Public Finance, University of Cologne, Max Planck Institute for Tax Law and Public Finance, University of Groningen - Faculty of Law, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Vienna University, Institute for Austrian and International TaxlawMax Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Independent, Deutscher Juristinnenbund e.V., Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Freshfields Bruckhaus Deringer LLP, University of St. Gallen, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance, Independent, Max Planck Institute for Tax Law and Public FinanceHgCapital, Max Planck Institute for Tax Law and Public Finance, Max Planck Institute for Tax Law and Public Finance and CMS Hasche SigleMax Planck Institute for Tax Law and Public Finance
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corporate law, business taxation, international tax law, debt equity distinction, comparative law, tax policy, comparative policy analysis

13.

Destination-Based Income Taxation and WTO Law: A Note

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2016-3
Number of pages: 18 Posted: 04 Feb 2016
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 882 (47,359)
Citation 22

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International taxation, multinationals, destination-based taxation, WTO law, GATT, ASCM

14.

Transfer Pricing – Business Incentives, International Taxation and Corporate Law

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2011-05
Number of pages: 19 Posted: 24 Jan 2011 Last Revised: 31 Oct 2011
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 836 (51,164)
Citation 2

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Transfer Pricing, International Taxation, Related Party Transactions, Multinational Enterprises, Corporate Groups, Taxing Rights

15.

Tax Legislation and the Notion of Fiscal Aid – A Review of Five Years of European Jurisprudence

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-14
Number of pages: 19 Posted: 22 Dec 2015
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 827 (51,772)
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16.

International Taxation of Risk

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2014-03
Number of pages: 31 Posted: 01 Mar 2014
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 774 (56,573)
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Tax Law, International Tax Policy, Risk and Taxation, Profit Allocation, Contractual Risk Allocation, Transfer Pricing, Arm’s Length Approach, Double Taxation Conventions, Risk Premium, Intangibles

17.

International Accounting Standards - A Starting Point for a Common European Tax Base?

European Taxation, Vol. 44, No. 10, 2004, p. 426-440
Number of pages: 15 Posted: 17 May 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 747 (59,349)

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European Tax Law, Accounting Standards, IAS, IFRS, International Tax Law, Business Taxation, Corporate Taxation, Company groups, common tax base

18.

Corporate Disclosure in a Competitive Environment - the Ecj's Axel Springer Case and the Quest for a European Framework for Mandatory Disclosure

ECGI - Law Working Paper No. 55/2006
Number of pages: 47 Posted: 03 Mar 2006
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 698 (64,877)
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European company law, competitive costs, capital and product markets, disclosure, innovative data, predatory pricing, mutual information, financial markets, mandatory disclosure, closely-held companies

19.

Free Movement of Capital and Freedom of Establishment

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-3
Number of pages: 29 Posted: 16 Jun 2015 Last Revised: 25 Jun 2015
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 680 (67,133)

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20.

Transfer Pricing, the Arm’s Length Standard and European Union Law

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2011-08
Number of pages: 45 Posted: 22 Sep 2011 Last Revised: 31 Oct 2011
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 669 (68,486)

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Transfer Pricing, Freedom of Establishment, International Taxation, Related-Party Transactions, Corporate Groups, International Tax Allocation

21.

Group Taxation and the CCCTB

Tax Notes International, Vol. 48, No. 11, pp. 1063-1080, 2007
Number of pages: 39 Posted: 15 Apr 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 597 (79,186)

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International Tax Law, Corporate Tax Law, Company Groups, Business Tax, Tax Competition, EC Law

22.

Is there Finally an International Tax System?

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2021-15
Number of pages: 31 Posted: 16 Sep 2021
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 556 (86,360)

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International Taxation, Tax Policy, Tax Law, BEPS, Tax Avoidance

23.

Neutrality and Territoriality — Competing or Converging Concepts in European Tax Law?

Bulletin for International Taxation April/May 2015, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-01
Number of pages: 25 Posted: 09 Jun 2015
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 494 (99,921)

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international tax law, European tax law, international tax allocation

24.

The Concept of Abuse of Law in European Taxation: A Methodological and Constitutional Perspective

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2019-18
Number of pages: 24 Posted: 21 Nov 2019
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 469 (106,322)

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Abuse of Law, European Taxation, European Law, European Court of Justice, Direct Taxation

25.

Is Everybody Obliged to Pay Taxes Somewhere?

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2023 - 09
Number of pages: 30 Posted: 26 Jul 2023
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 436 (116,834)

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26.

The Role of 'Commercial Reasons' and 'Economic Reality' in the 'Principle Purpose Test' under Art.29(9) OECD Model Tax Convention 2017

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2022-03
Number of pages: 22 Posted: 09 Feb 2022
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 415 (123,770)

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International Taxation, GAAR, OECD Model Tax Convention, Principal Purpose Tax, Commercial Reasons, Economic Reality

27.

Playing Different Games? Regulatory Competition in Tax and Company Law Compared

Common Market Law Review, Vol. 42, No. 2, pp. 331-335, 2005
Number of pages: 40 Posted: 16 Apr 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 400 (128,099)

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International Tax Law, Tax Regulation, Company Law regulation, Tax Competition, Corporate Tax law, Comparative Corporate Governance

28.

The Distinct Equity of the Debt-Equity Distinction

Bulletin for International Taxation, September 2012, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2014-08
Number of pages: 15 Posted: 03 Jun 2014
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 391 (131,470)

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corporate law, business taxation, international tax law, debt equity distinction, tax policy

29.

Attribution of Profits to PEs and the OECD 2006 Report

Tax Notes International, Vol. 46, No. 10, pp. 1059-1072, 2007
Number of pages: 33 Posted: 04 May 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 353 (147,160)

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Permanent Establishment, separate entity approach, international tax law, business tax law, corporate tax law, taxation, subsidiary

30.

Capital Gains Taxation in Germany

British Tax Review No. 6, pp. 620-627, 2005
Number of pages: 13 Posted: 04 Mar 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 318 (164,591)

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German tax law, income tax law, corporate tax, business taxation, capital gains, capital gains taxation

31.

Regulation and Taxation of the Financial Markets

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2016-8
Number of pages: 25 Posted: 05 May 2016
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 311 (168,545)

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32.

Tax Law Scholarship in Germany and the United States

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2016-7
Number of pages: 21 Posted: 05 May 2016
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 288 (183,291)
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33.

Interpreting European Law in the Light of the BEPS Action Plan

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2020-01
Number of pages: 29 Posted: 23 Jan 2020
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 280 (187,927)

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European Law, BEPS, International Tax Law, Tax Policy

34.

Statutory Avoidance and Disclosure Rules in Germany

BEYOND BOUNDARTIES - DEVELOPING APPROACHES TO TAX AVOIDANCE AND TAX RISK MANAGEMENT, Judith Freedman, ed., PP. 47-55, 2008
Number of pages: 13 Posted: 04 May 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 245 (214,675)

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German tax law, anti avoidance, anti abuse, income tax law, corporate tax law

35.

Value Creation, the Benefit Principle and Efficiency-Related Allocation of Taxing Rights

EATLP 2020 Congress Report (EATLP International Tax Series 19, (eds.) W. Haslehner and M. Lamensch, IBFD, Amsterdam, forthcoming, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2021-06
Number of pages: 12 Posted: 25 May 2021
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 231 (228,364)

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H20, H 25, H26, K33, K34

36.

Tax Strategy Patents - A Tax Lawyer's View

PATENTS AND TECHNOLOGICAL PROGRESS IN A GLOBALIZED WORLD, pp. 49-58, Martin J. Adelman, Robert Brauneis, Josef Drexl, Ralph Nack, eds., Liber Amicorum Joseph Straus, 2009
Number of pages: 13 Posted: 10 Jun 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 194 (267,158)

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Tax Law, Tax Planning, tax arrangements, Patent Law, business method patents, Tax Regulation

37.

Public Country-by-Country Reporting: Corporate Law, Fiscal Law and the Principle of Unanimity

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2021-14
Number of pages: 21 Posted: 02 Sep 2021
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 187 (276,079)

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European Law, Tax Law, European Treaties, OECD

38.

International Tax Rules for Unruly Times

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2023-08
Number of pages: 23 Posted: 20 Jul 2023
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 176 (292,582)

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39.

Losing Out at the Snooker Table: Cross-Border Loss Compensation for PE's and the Fundamental Freedoms

A VISIONS OF TAXES WITHIN AND OUTSIDE EUROPEAN BORDERS, FESTSCHRIFT IN HONOR OF FRANS VANISTENDAEL, L. Hinnekens, P. Hinnekens, eds., pp. 813-830, 2008
Number of pages: 23 Posted: 04 May 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 165 (307,708)

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International Tax Law, EC Law, Double Taxation Conventions, Corporate Tax Law, Business Tax Law, Fundamental Freedoms

40.

Special Charges - A Gap in European Competition Law?

European State Aid Law Quarterly, Vol. 5, No. 3, pp. 494-504, 2006
Number of pages: 25 Posted: 10 Jun 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 92 (476,613)

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State Aids, State Aid Law, European Tax Law, European Tax Regulation, EC Law, Community Law

41.

Some Thoughts on the Relationship between the Destination-Based Cash Flow Tax and VAT

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2023 - 07
Number of pages: 14 Posted: 20 Mar 2023
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law
Downloads 76 (534,788)

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Destination-Based Cash Flow Tax, WTO Law, VAT, international tax policy, destination principle

42.

Pre-Clearance in European Accounting Law - The Right Step?

PERSPECTIVES IN COMPANY LAW AND FINANCIAL REGULATION - ESSAYS IN HONOUR OF EDDY WYMEERSCH, pp. 231-243, Michel Tison, Hans De Wulf, Christoph Van Der Elst and Reinhard Steennot, eds., Cambridge University Press, 2009
Posted: 15 Apr 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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Financial reporting, SEC, disclosure, no action letter, accounting

43.

Abuse of Rights and European Tax Law

COMPARATIVE PERSPECTIVES ON REVENUE LAW - ESSAYS IN HONOUR OF JOHN TILEY, Cambridge University Press, pp. 75-98, John Avery Jones, Peter Harris, and David Oliver, eds., 2008
Posted: 15 Apr 2010
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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Anti Abuse, Anti Avoidance, International Tax Law, EC Law, Corporate Tax Law

44.

Balance Sheet Tests or Solvency Tests - Or Both?

European Business Organization Law Review (EBOR), Vol. 7, 2006
Posted: 19 Feb 2007
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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company law reform, distributions, dividends, accounting law, creditor protection, legal capital, balance sheet, solvency test

45.

The Odd Couple: A Common Future for Financial and Tax Accounting?

Tax Law Review, Vol. 58, No. 2, 2005
Posted: 08 Dec 2005
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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46.

The Future of Legal Capital

European Business Organization Law Review, Vol. 5, No. 3, pp. 429-448, 2004
Posted: 06 Apr 2005
Wolfgang Schoen
Max Planck Institute for Tax Law and Public Finance, Department of Business and Tax Law

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legal capital, informational asymmetry, collective offer, minimum capital requirement, solvency test, Überseering, Inspire Art, Centros, SLIM, High Level Group, capital maintenance, limited liability, Companies Bill 2002