The book provides a thorough study of the non-discrimination provisions of permanent establishments in international tax law. While the primary focus lies on the law of double taxation conventions, a significant part of the analysis is dedicated to compare and contrast the rules contained in bilateral treaties with the non-discrimination doctrine in place within the EU as a consequence of the Fundamental Freedoms. The analysis shows the importance of the double tax treaty network in order to provide comprehensive protection against discrimination of foreign enterprises even within the EU and how the two layers of supranational law and international law respectively interact. It is shown, for example, how this interaction may lead to an extension of the scope of the fundamental freedoms.

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This article analyses the ECJ case law on cross-border loss treatment with regard to permanent establishments, showing inconsistencies and misunderstandings with regard to the Court's "final losses"-doctrine and how to overcome these problems. It argues that the distinction between temporary and final losses is not only difficult to handle in practice, but is not convincing as a matter of principle and thus should be abolished.

"Refund of VAT for EU research projects as a consequence of the VAT exemption of the European Union" – the article examines the impact of a bilateral agreement between Austria and the EU on the EU's tax exemption with specific regard to the consequence for university research projects that are wholly or partly funded by the EU. It is shown that as a consequence of the interrelation of the procedural rules applied by the EU Commission to grant funding and the Austrian Ministry's of Finance understanding of how to refund VAT, the intentions of the bilateral agreement are frustrated.

"Taxes as forbidden state aid in respect of services in general economic interest?" – Chapter in Yearbook State Aid Law 2010: The contribution analyses case law of the ECJ and the CFI on the limits put by state aid rules on beneficial tax treatment for companies providing public services.

"Profit splitting for consortia in groups of companies"

"The role of consortia in Austrian Group Taxation"

"Disposal of shares in members of a group of companies"

The article discusses a judgement made by the Austrian Supreme Administrative Court with regard to corporate taxation of dividends from subsidiaries resident in other EU countries. The Court's decision is criticised for failing to ask the ECJ for a preliminary ruling on the issue despite the fact that it cannot be considered "acte claire". It is shown that despite the ECJ's apparent acceptance of a free choice between an exemption and a credit system for foreign dividends to be made at the Member States' discretion, the credit system may often result in disadvantages for taxpayers that cannot be regarded as mere disparity.

"Abusive claim for tax exemption in cross-border trade – consequences from the viewpoint of VAT law and criminal law" – Chapter in conference volume, Linde Verlag, Vienna 2008.

"VAT for services performed between insurance companies in Austria"

"No VAT exemption for cession of insurance contracts – AG Opinion in case Swiss Re"

"Deductible Expenses in assessment of withholding tax for income from capital"

"ECJ case Wannsee in comparison to AMID, Shell and Lidl Belgium – PE losses revisited"

"The state of competition among EC fundamental freedoms in ECJ case law regarding direct taxes"

"Group Taxation: Financial Link via foreign companies as members of a group"

"Questions of doubt in Group Taxation: Rivalry between optional ways to constitute a financial link between companies"

"ECJ judgement in the Netto Supermarkt case: Protection of bona fide rights extended to third country trade"

2ECJ judgement in the Deutsche Shell case (C-293/06): Bringing an end to the German proposition of symmetry?"

"Extension of the Fundamental Freedoms of EC Law through constitutional and tax treaty law"

"Group relief in European Tax Law – ECJ in conflict with his decision in Marks & Spencer?"

"The Freedom of movement of capital in relation to third countries: foreign dividends"

"The Relevance of EC Fundamental Freedoms in Relation to Switzerland"

"Inheritance Tax in case of substitutional inheritance: beneficial arrangements regarding cases of succession before 31 July 2008"