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WU Vienna Tax law


Helmut Loukota

Born in 1940, he received his doctor’s degree from the University of Vienna in 1962. In that year, he also joined the Austrian tax administration. In 1988, he was appointed director of the Division for International Tax Law in the Ministry of Finance and also acted in that capacity as head of the Austrian delegations in the Austrian tax treaty negotiation process. In the course of his work for the OECD he was vice chairman of the OECD Working Party on Double Taxation and chairman of the Working Group on Partnerships. In 2000, he became honorary professor. He is author of several books and numerous articles, developed and drafted the Austrian Transfer Pricing Guidelines 2010 for the Ministry of Finance, is senior lecturer at WU and teaches at the Austrian Federal Tax Academy.

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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