The Master's thesis will be up to 20 pages in length. Research on one general topic must be carried out in each study program. The theses of the 2009/2010 full-time program will be based on the theme of "European Union and Third Countries"; the theses of the 2010/2011 full-time program will cover the topic of "The Relevance of OECD Documents for the Interpretation of Bilateral Tax Treaties". The theses of the 2009/2011 part-time program will be on the subject of "Permanent Establishments in International Tax Law".

The subject of each thesis will be agreed between the Academic Director and the student (and will be based on the general topic covered in the course), and a lecture will be held on the general topic itself. Two further seminars will be held relating to the style in which the thesis should be written, and the various methods and techniques involved, and will also give students the opportunity to present, discuss and debate the ideas and concepts from their work.

 
European Union and Third Countries
Pistone, Pasquale,, F 09/10

European tax law is no longer just a matter for the internal market, but also a source of rights in respect of relations with third countries. Starting from a comparison between the broad differences in two such scenarios, this teaching module will categorize third countries as a function of their type of relations with the European Union and its laws. Such a categorization will then be used to analyze selected tax issues, taking into account the relevant case law (European Court of Justice and those of national courts, including third countries), the applicable treaties (e.g. Economic and Partnership Agreements, Savings Agreements, Bi- and Multilateral Tax Conventions) and domestic tax rules. The focus of this teaching unit will be mainly on direct taxation.

F 09/10: October 9-10, 2009

 
European Union and Third Countries -
Seminar II /Seminar III
Heidenbauer, Sabine, F 09/10
Stürzlinger, Virgit, F 09/10

Both of these courses are directly linked to the introductory classes on this topic and will be held while students are working on their Master's theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research, using international literature and its systematic preparation. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.

F 09/10, Seminar II: January 14-16, 2010 F 09/10, Seminar III: 'April 8-10, 2010

 
The Relevance of OECD Documents for the Interpretation of Bilateral Tax Treaties
Reimer, Ekkehart, P 10/11

Since its foundation in 1948/1961 and the publication of its first Model Double Taxation Convention, the OECD has gained undisputed leadership, authority and expertise in the field of tax treaties. The course reflects on the early days of OECD and tries to mark the decisive steps in the evolution of what has now become a highly sophisticated network of rules and reports, customs and institutions on international taxation. The idea is that understanding the historic environment of a rule and of its travaux préparatoires (cf. Art. 32 of the Vienna Convention on the Law of Treaties) is a valuable means of interpretation - but that such understanding is also helpful for any future reformatting of tax treaty law in Europe and worldwide. By role playing and the in-depth analysis of archive material, participants will learn to utilize OECD archive material, assess its historic relevance, and connect it to up-to-date issues of tax treaty law. In doing so, the course aims at equipping all students with sound methodological skills for the LL.M. theses

F 10/11 October 8-9, 2010

 
The Relevance of OECD Documents for the Interpretation of Bilateral Tax Treaties -
Seminar II /Seminar III
Ecker, Thomas, F 10/11
Ressler, Gernot, F 10/11

Both of these courses are directly linked to the introductory classes on this topic and will be held while students are working on their Master's theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research, using international literature and its systematic preparation. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.

F 10/11 January 13-15, 2011
F 10/11 April 7-9, 2011

 
Permanent Establishments in International Tax Law
Garcia Prats, F. Alfredo, P 09/11

This course analyzes the concept of and the different types of permanent establishments, the importance of permanent establishments in trans-national businesses, and the functions of the PE clauses in domestic tax law and double tax treaties. Special attention to construction projects, auxiliary activities, agents and sales representatives and to supply chain structures will be given. The attribution of profits to permanent establishments will also be dealt with, with special reference and analysis to the OECD Guidelines in this regard. Attention will be paid to the influence of EC law for the taxation of permanent establishments in international tax law.

P 09/11: October 30-31, 2009

 
Permanent Establishments in International Tax Law
Seminar II (2)/ Seminar III (2)
Brugger, Florian, P 09/11
Plansky, Patrick, P 09/11

Both of these courses are directly linked to the introductory classes on this topic and will be held while students are working on their Master's theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research, using international literature and its systematic preparation. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.

F 09/11, Seminar II: September 21-23, 2010
F 09/11, Seminar III: September 16-18, 2010