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WU Vienna Tax law


Raffaele Russo

Rafa is the head of the BEPS Project at the OECD Centre for Tax Policy and Administration, and he has direct responsibility for the work on the digital economy. Previously, Rafa was head of the Non-Compliance Unit at the OECD Centre for Tax Policy and Administration, in charge of the work on Aggressive Tax Planning and on Tax Crimes. Rafa regularly leads OECD missions in non-member countries and at the OECD Multilateral Centres. Before joining the OECD, he was a senior associate at the International Tax Academy of the IBFD (Amsterdam) and a tax lawyer with NCTM Studio Legale Associato (Milan). He obtained his law degree from the University Federico II (Naples, Italy), and his LLM in international taxation from the University of Leiden in the Netherlands, both cum laude. He is the author of several articles and books on international tax matters including ‘The Attribution of Profits to Permanent Establishments: The taxation of intra-company dealings’ (2005) and ‘Fundamentals of International Tax Planning’ (2007).

International tax planning has gained a lot of attention from both the perspective of taxpayers and tax authorities. This course deals with the building blocks of international taxation, such as the concept of permanent establishment and the arm’s length principle, as applied for international tax planning purposes. It focuses on the boundaries between legitimate tax planning, tax avoidance, and tax evasion, by analyzing relevant case law. Finally, it deals with some tax planning schemes for multinational enterprises and the current debate around tax compliance.

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