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WU Vienna Tax law


Silke Bruns

After qualifying as a lawyer in Germany (Bavaria), she worked for three years for the German tax administration in Mecklenburg-Western Pomerania before joining the German Federal Ministry of Finance in 2003. In this capacity, she spent 2005/06 at the Centre for Tax Policy and Administration of the OECD, focussing on tax treaty non-discrimination issues. Mainly working in the area of international taxation, she also gained experiences in public relations, namely as a spokesperson for the Ministry of Finance in the years 2011 to 2013. Since 2016, she is as Head of Division in charge of, amongst other international issues, the negotiation of tax treaties with EU/EEA Member States and the effect of European primary law on direct taxation.

This course will allow students to examine the main policy and technical issues involved in the negotiation of tax treaties. It will first explore the main elements that determine a country's tax treaty policies, including the relevant features of its domestic tax system and economic factors. It will then focus on the identification of the main issues involved during the negotiation of each article of a typical tax treaty. The course will also examine the various steps for the conclusion of a tax treaty and the process of negotiation, taking into account the role of model conventions and previously concluded treaties.

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