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WU Vienna Tax law


Liselott Kana

Born in Stockholm in 1955, she graduated from Stockholm University with a Bachelor of Law degree and went on to get a Master of Law at the London School of Economics in 1984. After working for Arthur Andersen in London, she has, since 1990, been involved in international issues in Chile, first at the Ministry of Economy (Foreign Investment Committee) and then at the Ministry of Foreign Affairs. In 1997, she was appointed head of international taxation at the Revenue Agency in charge of, amongst other international issues, the negotiation of taxation treaties. She teaches international taxation at the Catholic University in Santiago and was a member of the United Nations group of tax experts between 2009 and 2017.

The course provides a short introduction to doing business in general in South America, touching on the Agreements for the Protection of Foreign Investment and the Free trade initiatives in the Americas, including tax provisions in such agreements. The trend towards tax treaties in the region is analyzed, including parts of the Andean Pact and the OECD and UN Model as applied by South American countries. Some specific differences and special issues in tax treaties in the region are presented and discussed.

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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