Description

About the Seminar

The OECD has developed technical materials, which provide an important contribution to the interpretation of tax treaties. Those materials are often described as soft international tax law. They include the Commentaries on the OECD Model Tax Conventions, the OECD Transfer Pricing Guidelines, the Explanatory Statement to the BEPS MLI, the Agreed Administrative Guidance on Pillar 2, the OECD Manuals on Mutual Administrative Assistance and Mutual Agreement Procedures, the OECD reports and studies, etc. The lecture will provide an overview of the technical relevance of such materials, addressing them from the perspective of the Vienna Convention on the Law of Treaties and in the light of the general principles of international law. The analysis will address the different perspectives of OECD countries and non-OECD countries.

About the Speaker

Prof Pasquale Pistone has been a member of the Institute for Austrian and International Tax Law since 2005, where he holds an ad personam Jean Monnet Chair in European Tax Law and Policy. He is also a Full Professor of Tax Law at the University of Salerno (Italy) and the Academic Chairman of the International Bureau of Fiscal Documentation (a research institute operating in Amsterdam since 1938). His permanent legal research focuses on European and international tax law and includes an interdisciplinary approach to a wide range of issues that arise in both areas. Long-term specific areas of interest include the protection of taxpayers’ rights as human rights, constitutional principles applicable to tax law, cross-border tax dispute settlement (under tax and bilateral investment tax treaties), transparency and cross-border mutual assistance in tax matters and the relations with developing countries. Chief editor of the journals World Tax Journal and of ITAXS, the IBFD Doctoral Series and the Series of International Tax Lawby Bloomsbury and of the IBFD Global Tax Treaty Commentaries. (Co-)Editor of 78 books and (co)-author of 9 books and of over 270 articles and book chapters on tax law, written and/or translated in 12 languages, mostly on international and European tax law.