Assigment of Taxing Rights (Source Taxation vrsus Residence Taxation; Double Non-Taxation)

Issues of international taxation are increasingly becoming the focus of by decision makers in the world of business and politics. As a result of globalization and the increasing interdependence of national economies, problems of cross-border taxation are becoming more frequent. Entrepreneurs and investors must therefore develop strategies to avoid double or multiple taxation when doing cross border business in order not to get "punished" for the cross border activities. National governments, on their part, must also take into account the fiscal environment when considering ways of making their country attractive for business. In an attempt to avoid the negative consequences of ruthless tax competition, increasing efforts are being undertaken to coordinate national taxation systems. In the debate on international tax coordination the SFB will put a regional focus on the European Union. The participation of scientists who are researching at the Vienna University of Economics and Business Administration in the field of tax subjects from legal, financial, economical, business and historical points of view enables the crucial analysis of the underlying concepts on the coordination of the existing tax systems from different angles. In particular, the SFB will focus on the budgetary consequences of international tax coordination for the EU member states as well as on the effects on companies under tax burden aspects. Hereby, the tax burden on cross-border direct investment is on the agenda as well as the tax burden borne by mobile employees. Special attention will be paid to bilateral tax treaties and their role in international tax coordination efforts. Those treaties are international contracts which either permit a State to or prohibit a State from taxing one and the same income earned on the market. In case of cross border activities double taxation can be avoided by the application of tax treaties. On the other hand, occasionally double non-taxation may arise. The SFB will analyze to which extent tax treaties may have an impact on international tax coordination efforts. It aims at answering the question whether tax harmonization, tax competition or tax coordination is "the" strategy when taxing cross border activities and will provide concepts for policy makers.