Prof. Dr. Alexander Rust, LL.M.

I. Lectures/Seminars/Visiting Professorships

1. National Reporter for Germany on “The Proposed Directive to Ensure a Minimum of Effective Taxation of Savings Income,” University of Graz (Austria), High Level Scientific Conference, European Union, September 1999.

2. National Reporter for Germany on “Avoidance of Double Non-Taxation,” University of Vienna (Austria), High Level Scientific Conference, European Union, June 2002.

3. National Reporter for Germany on “CFC Legislation, Tax Treaties and EC Law,” University of Vienna, (Austria), High Level Scientific Conference, European Union, July 2003.

4. Visiting Professor at the LL.M. Program International Taxation, Leiden (Netherlands), October 2003.

5. Visiting Professor at the University of Almaty (Kazakhstan), teaching introductory course in International Taxation on behalf of the EU, September 2004.

6. National Reporter for Germany on “Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law,” University of Milan (Italy), OECD Conference, November 2004.

7. Lecture on “Most Favored Nation Clauses in Double Taxation Conventions,” Max-Planck-Institute Munich (Germany), September 2005.

8. National Reporter for Germany on “Recent and Pending Cases at the ECJ,” University of Vienna (Austria), High Level Scientific Conference, European Union, October 2005.

9. National Reporter for Germany on “Tax Treaties and Domestic Law,” University of Milan (Italy), OECD Conference, November 2005.

10. Lecture at the Academy of the German Ministry of Finance in Berlin (Germany) on “Recent Developments in EC Tax Law,” December 2005.

11. Visiting Professor at the tax administration in Accra (Ghana) on “How to Create a Business Friendly Investment Climate in Developing Countries”, one week training program on behalf of the German “Gesellschaft für Technische Zusammenarbeit”, August 2006.

12. Lecture at the University of Münster (Germany) on “Triangular Cases in International Tax Law” during the Summer Course in International Taxation, July 2007.

13. Tax Expert on CFC legislation and Compatibility with EU Law at the Commission of the European Union, September 2007.

14. Lecture at the University of Vienna (Austria) on “Art. 21 OECD-Model Convention” during a conference on distributive norms in tax treaties, November 2007.

15. Visiting Professor at the LL.M. Program in International Taxation, Leiden (Netherlands) on “Non Discrimination in International Tax Law”, November 2007 (Evaluation: 4.75 [highest grade: 5] average of all lecturers: 4.21).

16. Lecture at the University of Tilburg (Netherlands) on “Abuse in International Tax Law”, November 2007.

17. Lecture at the Academy of the German Ministry of Finance in Berlin (Germany) on “Recent Developments in EC Tax Law,” December 2007.

18. Lecture at the University of Lisbon (Portugal) on “CFC Legislation and EC Law”, May 2008.

19. Two Day Course on “International Taxation” at the law firm “Pöllath&Partners”, July 2008.

20. Lecture at the University of Münster (Germany) on “Triangular Cases in International Tax Law” during the Summer course in International Taxation, July 2008.

21. Panelist at Seminar I: Non-discrimination at the 2008 congress of the International Fiscal Association in Brussels, September 2008.

22. Lecture at Seton Hall Law School (New Jersey, USA) on “Secondary Community Law in the Area of Direct Taxation”, March 2009.

23. Lecture at Seton Hall Law School (New Jersey, USA) on “Free Movement of Capital” at the conference on Free Movement in the European Union, April 2009.

24. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention” and on “The Parent Subsidiary Directive” during the Summer Course in International Taxation and Corporate Governance, June 2009.

25. Lecture at the University of Münster (Germany) on “Triangular Cases in International Tax Law” during the Summer Course in International Taxation, August 2009 (Evaluation: 1.43 [highest grade: 1].

26. Visiting Professor at the LL.M. Program in International Taxation, Leiden (Netherlands) on “The interaction between tax treaties and CFC regimes” and “Non Discrimination in International Tax Law”, November 2009 (Evaluation: 4.42 [highest grade:5] average of all lecturers: 3.92).

27. Comments on “Investor taxation in open economies” by Desai and Dharmapala, Conference on tax treaties from a legal and economic perspective, University of Vienna, March 2010.

28. Lectures on “Juridical double taxation” and “EU law as a remedy to double burdens”, University of Luxembourg, April 2010.

29. Comments on “The EU’s approach towards harmful tax competition and tax fraud” by Servaas van Thiel, Second Symposium on EC Tax Policy, University of Linz, May 2010.

30. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention” and on “The Freedom of Establishment” during the Summer Course in International Taxation and Corporate Governance, June 2010.

31. Lectures at the University of Lisbon (Portugal) on “Cross-border losses” and “Dividend taxation within the European Union” during the GREIT Summer Course on European Tax Law, June 2010.

32. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2010.

33. Lecture at the University of Münster (Germany) on “Double Taxation Treaties: Recent developments (Case studies) during the Summer Course in International Taxation, August 2010 (Evaluation: 1.19 [highest grade: 1].

34. Visiting Professor at the LL.M. Program in International Taxation, Leiden (Netherlands) on “The interaction between tax treaties and CFC regimes” and “Non Discrimination in International Tax Law”, November 2010.

35. Lecture at the University of Milan / OECD Conference on “Interpretation of the terms “business” and “business profits” in the OECD-MC, November 2010.

36. Lecture at the University of Luxembourg on “Data protection as a fundamental right”, November 2010.

37. Lecture at the University of Münster (Germany) on “International business taxation”, December 2010 (Evaluation: 1,44 [highest grade: 1].

38. Keynote Lecture at the D-A-CH congress in Vienna on ”Future Trends in European Tax Law”, March 2011.

39. Lecture at the University of Luxembourg on “Taxation of Investment Funds”, April 2011.

40. Lecture at the University of Luxembourg on “Common Consolidated Corporate Tax Base”, May 2011.

41. Lecture at the University of Vienna on “German Tax Law”, May 2011.

42. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, on “The EU Directives”, “EU tax law: outbound”, and “Comparative Fiscal Federalism: EU and the US” during the Summer Course in International Taxation and Corporate Governance, June 2011.

43. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2011.

44. Lecture at the University of Münster (Germany) on “Special Tax Regimes” during the Summer Course in International Taxation, July 2011 (Evaluation: 1.25 [highest grade: 1]).

45. Lectures at the Taxand Junior School in Marbella (Spain) on “Introduction to Tax Treaties”, “Passive Income”, “CCCTB”, and “Beneficial Ownership”, October 2011.

46. Visiting Professor at the LL.M. Program in International Taxation, Leiden (Netherlands) on “The interaction between tax treaties and CFC regimes” and “Non Discrimination in International Tax Law”, November 2011.

47. Moderator at the Conference “State Aid and Tax Law” at the University of Luxembourg, November 2011.

48. Moderator at the Annual Conference on European Direct Taxation at the ERA-Academy of European Law Trier, November 2011.

49. Panelist at the Gala CFO World 2011 in Luxembourg, November 2011.

50. Lecture at the Tax Conference "Fiscalité Luxembourgoise" in Luxembourg on "Latest Developments in EU Tax Law", December 2011.

51. Lecture at the ATOZ Tax Conference in Luxembourg on "Taxation of Frontier Workers", December 2011.

52. Lecture at the Tax Department of Arcelor/Mittal in Luxembourg on “Non-discrimination in Tax Law”, March 2012.

53. Lecture at the University of Luxembourg on “Les accords Rubik”, March 2012.

54. Lectures at the Taxand Junior School in Marbella (Spain) on “Introduction to Tax Treaties”, “Passive Income”, “Beneficial Ownership”, and ECJ Developments”, March 2012.

55. Lecture at the University of Vienna (WU) on the “Taxation of Foreign Income”, April 2012.

56. Lecture at the Institut Finanzen und Steuern Berlin on “The Tax Agreements with Switzerland from a Constitutional and EU-law Perspective”, May 2012.

57. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, on “The EU Directives”, “EU tax law: outbound”, and “Comparative Fiscal Federalism: EU and the US” during the Summer Course in International Taxation and Corporate Governance, June 2012.

58. National Reporter for Germany on “Tax Treaty Case Law Around The Globe,” University of Tilburg (Netherlands), June 2012.

59. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, July 2012.

60. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2012.

61. Lecture at the University of Münster (Germany) on “Overview of Special Tax Regimes” during the Summer Course in International Taxation, July 2012 (Evaluation: 1.57 [highest grade: 1]).

62. Lecture at the seminar of the “Deutsche Steuerjuristische Gesellschaft” at the University of Linz (Austria) on “Principles of Equality and Non-discrimination”, September 2012.

63. Panelist in Seminar L: “Limitations on Benefit Articles in Income Tax Treaties: The Current State of Play” at the 2012 congress of the International Fiscal Association in Boston, October 2012.

64. Panelist at the E&Y Tax Club on CCCTB, Luxembourg, October 2012.

65. Lecture at the University of Vienna on “German Tax Law”, November 2012.Lectures at the Tax Department of ATOZ in Luxembourg on “Non-discrimination in Tax Law” and “Beneficial Ownership Provisions”, October 2012.

66. Panelist at the Arendt Financial Law Forum on “Exchange of Information” in Mondorf-les-Bains (Luxembourg), November 2012.

67. Lectures at the Tax Department of ATOZ in Luxembourg on “Interpretation of Tax Treaties” and “Latest Developments in EU Tax Law”, November 2012.

68. Lecture at the University of Milan (Italy) / OECD Conference on “Issues of Qualification under Article 23 OECD MC”, November 2012.

69. Lecture at the University of Luxembourg on “The Financial Transaction Tax”, December 2012.

70. Lecture at the 29th congress on International Taxation in Hamburg on “Double Non-Taxation”, December 2012.

71. Keynote speech at the University of Hamburg on “The Future of Taxation”, December 2012.

72. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, January 2013.

73. Lecture at the University of Amsterdam (Netherlands) on “Non-discrimination”, January 2013.

74. Jean Monnet-Lectures at the University of Valencia (Spain) on “General Anti-abuse Provisions in Tax Law” and “Compatibility of CFC-legislation with Tax Treaty and EU Law”, January 2013.

75. Lecture at the University of Luxembourg on “Pensions in International Tax Law”, April 2013.

76. Presentation of the Luxembourg National Report on “Exchange of Information” at the Luxembourg IFA Branch, April 2013.

77. National Reporter for Germany on “Tax Treaty Case Law Around The Globe,” University of Vienna (Austria), May 2013.

78. Lecture at the the E&Y Tax Club on “The Future of International Tax Planning, Luxembourg, May 2013.

79. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law: outbound”, and “Comparative Fiscal Federalism: EU and the US” during the Summer Course in International Taxation and Corporate Governance, June 2013.

80. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, July 2013.

81. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2013.

82. Lecture at the University of Münster (Germany) on “Overview of Special Tax Regimes” during the Summer Course in International Taxation, July 2013 (Evaluation: 1.07 [highest grade: 1]).

83. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, September 2013.

84. Lecture during the annual seminar of the German tax journal “International Taxation” (IStR) in Berlin on “The new Tax Convention between Germany and Luxembourg”, October 2013.

85. Lectures at the University of Leiden (Netherlands) on “CFC regimes” and “Non Discrimination in International Tax Law”, October 2013.

86. Lecture at the University of Vienna on “German Tax Law”, November 2014.

87. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, January 2014.

88. Lecture at the University of Amsterdam (Netherlands) on “Non-discrimination”, January 2014.

89. Lecture at the University of Luxembourg on “Mutual Recognition and Neutralisation – Denkavit Internationaal” and commentator for the lecture “Subjective Ability to Pay – Schumacker” by Prof. Dr. Alfredo Garcia Prats, January 2014.

90. Lecture at the University of Luxembourg on “Latest Trends in Luxembourg Tax Law” (in French), February 2014.

91. Panelist at the Lecture of Professor Daniel Shaviro at the University of Luxembourg on “A one-time Capital Levy, May 2014.

92. Presentation of the Book “Fixing U.S. International Taxation of Professor Daniel Shaviro at the University of Luxembourg, May 2014.

93. Lecture at CREA Conference Talks on Economics at the University of Luxembourg on “Hybrid Mismatch Arrangements”, May 2014.

94. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law: outbound”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation and Corporate Governance, June 2014.

95. Lecture at the 20^th Anniversary Conference of the EFTA Court on “Taxing Europe: Reflections on the Case Law of the EFTA Court” Luxembourg, June 2014.

96. Lecture at the Institute of Luxembourg Administrators (Luxembourg) on “Tax Law for Directors”, July 2014.

97. Panelist at the Conference at the Wirtschaftsuniversität Wien on “General Anti-Avoidance Rules”, July 2014.

98. Panelist at the “Tenth Annual Eurasia Fiscal Experts’ Seminar” at the Tax Policy Center of the Wirtschaftsuniversität Wien, July 2014.

99.  Lecture at the University of Münster (Germany) on “Overview of Special Tax Regimes” during the Summer Course in International Taxation, July 2014.

100. Graduation lecture at the ITC Leiden (Netherlands) on “Article 3(2) OECD MC” together with John F. Avery Jones and Frank Engelen, August 2014.

101.   Lecture at the Wirtschaftsuniversität Wien given to judges of the Supreme Court of Thailand on “International Tax Planning: Latest Developments with regard to Austria and Thailand”, September 2014.

102. Chairman of the panel on “The Treatment of Digital Supplies and Other E-Services Under VAT B2C vs B2B” at the Wirtschaftsuniversität Wien conference on “The Future of VAT in a Digital Global Economy”, September 2014.

103. Two day lecture at the LL.M. Program International Taxation at the Wirtschaftsuniversität Wien on “The Non-discrimination Article in Tax Treaties”, September 2014.

104. Lecture at the LL.M. Alumni Reunion at the Wirtschaftsuniversität Wien on “BEPS: Hybrid Mismatch Arrangements”, October 2014.

105.  Lecture at the Max-Planck-Institute Munich on “The Compatibility of the BEPS Proposals on Action 2 with the EU Fundamental Freedoms”, November 2014.

106.  Inaugural Lecture at the Wirtschaftsuniversität Wien on “Reforming the Austrian Tax System”, November 2014.

107. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxtion,” Presentation of the Cases C-241/14 (Bukovansky), C-388/14 (Timac Agro) and C-591/13 (Comm. v. Germany), Wirtschaftsuniversität Wien, November 2014.

108. Chairman of the panel on “Supply of Goods and Services”, “Tax Base / Tax Rate” and “Abuse and VAT” at the Wirtschaftsuniversität Wien conference on “Court of Justice of the European Union: Recent VAT Case Law”, December 2014.

109. Two day lecture at the master program of the University of Luxembourg on “Triangular Cases”, December 2014.

110. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law” (January 2015).

111. Lecture on “Tax Treaty Entitlement, Abuse of Tax Treaties – Where are the Limits?, Akademie der Wirtschaftstreuhänder Vienna, January 2015.

112. Lecture on “How Final are Arbitration Decisions?, International Arbitration in Tax Matters Conference at the Wirtschaftsuniversität Wien, January 2015.

113. Lecture on “Equality and Non-Discrimination”, Conference on “Primary Law Limits to Direct Taxation” at the University of Luxembourg, January 2015.

114. Lecture on “OECD Measures on Hybrid Mismatch Arrangements and their Compatibility with EU Law”, Max-Planck-Institute München, Germany, February 2015.

115. Lecture on “Interpretation of Tax Laws”, Responses to the Wolfgang Gassner Gedächtnisvorlesung given by Joachim Englisch, Vienna, April 2015.

116. Lecture on “Interpretation of Tax Treaties”, Bucharest, April 2015.

117. Lecture on “Timing Issues in Tax Treaties”, Tilburg, April 2015.

118. Lecture on “Compatibility of Patent Box Regimes with the State Aid Provisions”, Steuerrechtstag Waidhofen an der Ybbs, Mai 2015.

119.  Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law: outbound”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation, June 2015.

120. National Reporter for Austria at the “Tax Treaty around the Globe Conference,” Presentation of the Case SV 2/2013 decided by the Austrian Constitutional Court on 23 June 2014, Wirtschaftsuniversität Wien, June 2015.

121. Lecture on “Anti-Abuse Clauses for Permanent Establishments Situated in Third Countries” (together with Viktoria Wöhrer), Vienna, June 2015.

122. Lectures at the University of Lisbon (Portugal) on “The BEPS proposals on hybrid mismatches” and “The BEPS proposals on CFC legislation“ during the GREIT Summer Course on European Tax Law, June 2015.

123. Lectures at the University of Krakow on “The Fight against Double Non-Taxation” and “Interpretation of Tax Treaties”, July 2015.

124. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2015.

125. Lecture on “Action 15 of the BEPS Action Plan”, WU Presentation at the IFA Congress Basel, September 2015.

126. Lecture at the University of Halle-Wittenberg, Annual Conference of the Deutsche Steuerjuristische Gesellschaft on “WTO Law and Tax Law”, September 2015.

127. Lecture on “Recent Trends in the Jurisprudence of the ECJ”, Kammer der Wirtschaftstreuhänder, Vienna, September 2015.

128. Lecture at the University of Leiden (Netherlands) on “Non-discrimination in International Tax Law”, October 2015.

129. Lecture at the LL.M. Program International Taxation at the Wirtschaftsuniversität Wien on “The Non-discrimination Article in Tax Treaties”, November 2015.

130. Lecture at the University of Luxembourg on “Double Taxation within the European Union, Open Issues and Remaining Challenges”, November 2015.

131. Lecture at the University of Milan (Italy) / OECD Conference “The Taxation of Entertainers and Sportspersons Performing Abroad” on “The Influence of EU law on Domestic Law”, November 2015.

132. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxtion,” Presentation of the Cases C-479/14 (Hünnebeck), C-522/14 (Sparkasse Allgäu) and C-123/15 (Feilen), Wirtschaftsuniversität Wien, November 2015.

133. Two day lecture at the master program of the University of Luxembourg on “Triangular Cases”, December 2015.

134. Lecture at the IFA Luxembourg branch on “Tax reforms in Germany and Austria: Role models for Luxembourg?” December 2015.

135. Lecture on “Tax Treaty Entitlement, Abuse of Tax Treaties – Where are the Limits?, Akademie der Wirtschaftstreuhänder Vienna, January 2016.

136. Lecture on “Recent Trends concerning the Interpretation of Double Taxation Conventions”, Kammer der Wirtschaftstreuhänder, Vienna, March 2016.

137. National Reporter for Germany at the “Tax Treaty around the Globe Conference,” University of Tilburg, Netherlands, May 2016.

138. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law: outbound”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation, June 2016.

139. Lecture on “Dependent and Independent Personal Services” (together with Benjamin Walker), Vienna, June 2016.

140. Panelist at the Workshop “Hybrid Mismatch Arrangements”, Berliner Steuergespräche, Berlin, Germany, June 2016.

141. Lecture at the University of Münster (Germany) on “Overview of Special Tax Regimes” during the Summer Course in International Taxation, June 2016 (Evaluation: 1.00 [highest grade: 1.00]).

142. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2016.

143. Panelist at the IFA WU Seminar “Taxation of Services according to the UN MC”, Madrid, Spain, September 2016.

144. Lecture at the Complutense University in Madrid, Spain on “CFC Rules in Light of EU Law and the BEPS Project”, October 2016.

145. Lecture at the Global Henkel Tax Campus on “Country-by-Country Reporting”, Vienna, October 2016.

146. Lecture at the Austrian IFA Branch on “Articles 7 and 8 of the Anti-Tax-Avoidance Directive”, Vienna, October 2016.

147. Lecture at the Master of Legal Studies Program at WU Vienna on “Introduction to International Tax Law”, Vienna, October 2016.

148. Two day lecture at the master program of the University of Luxembourg on “Triangular Cases” and the “Multilateral Instrument”, Luxembourg, December 2016.

149. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2017.

150. Lecture at the University of Luxembourg on “Time and Distributive Rules in Tax Treaties” (together with Georg Kofler), Luxembourg, January 2017.

151. Moderator at the IFA event “Dispute Resolution“, Vienna, Austria, February 2017

152. Lecture at the IFA Cape Town on “The UN Technical Services Fees Article and Services-Based Permanent Establishments”, Cape Town, South Africa, February 2017

153. Lecture at the IFA Johannesburg on “The UN Technical Services Fees Article and Services-Based Permanent Establishments”, Johannesburg, South Africa, February 2017

154. Lecture on “Trends and Developments of CJEU Case Law on Fundamental Freedoms”, WU Vienna, Austria, February 2017

155. Panelist at the seminar „US Tax Reform: Realizing the dream or Europe’s worst nightmare!“ with Robert Stack, WU Vienna, Austria, March 2017

156. Lecture on “Substance over Form Doctrine in Tax Treaty Law”, Responses to the Wolfgang Gassner Gedächtnisvorlesung given by Klaus-Dieter Drüen, WU Vienna, April 2017

157. Lecture on “Why do we need taxes?”, Children’s University, WU Vienna, April 2017

158. Lecture at the Global Henkel Tax Campus on “The Service Permanent Establishment and Assignment of Revenues to a Permanent Establishment”, Vienna, May 2017

159. Lecture on “The changes regarding the Permanent Establishment Definition in the Multilateral Instrument”, Conference Implementing BEPS: the Challenges Facing China, WU Vienna, May 2017

160. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation, June 2017

161. Lecture on “Options under the Multilateral Instrument” (together with Alexandra Miladinovic), Vienna, June 2017.

162. Lecture on "Taxation in the Digital Economy", IFA Panel, Rio de Janeiro, Brazil, August 2017.

163. Lecture on “The Principal Purpose Test”, Kickoff Seminar at the occasion of the inauguration of the VU Nexus Centre, Amsterdam, Netherlands, October 2017.

164. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxtion,” Presentation of the Cases C-20/16 (Bechtel & Bechtel), C-685/16 (EV) and C-135/17 (X-GmbH), Wirtschaftsuniversität Wien, November 2017.

165. Lecture at the LL.M. Program International Taxation at the Wirtschaftsuniversität Wien on “The Non-discrimination Article in Tax Treaties”, December 2017.

166. Two day lecture at the master program of the University of Luxembourg on the “Multilateral Instrument”, Luxembourg, December 2017.

167. Lecture at the Digital Tax Transformation conference at WU Vienna on “Adapting the PE Concept to a Virtual World”, Vienna, December 2017.

168. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2017.

169. Moderator at the symposium “Value Added Tax and Digitalization” at WU Vienna, Vienna, May 2018.

170. Presentation of the Report “Fundamental Rights in Tax Law” at the Austrian Lawyers’ Association (together with Daniel Blum), May 2018.

171. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation, May/June 2018.

172. Lecture at the LL.M. Program International Taxation at WU Vienna on “Tax Treaties: Planning and Specific Interpretation Issues”, June 2018.

173. Panelist at the Honorary Lecture of Stephanie Hoffer at WU Vienna, June 2018.

174. Lecture on “Dual Residence for Individuals” (together with Karol Dziwiński) at WU Vienna, June 2018

175. Lecture on the “Multilateral Instrument and the Principle Purpose Test” at Workshop Procter&Gamble Vienna, October 2018.

176. Lecture on the “EU Draft Directives regarding the Taxation of the Digitalized Economy” at Chamber of Tax Advisors and Certified Public Account Accountants Vienna, October 2018.

177. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxtion,” Presentation of the Cases C-382/16 (Hornbach), C-480/17 (Montag), C-685/16 (EV) and C-135/17 (X-GmbH), Wirtschaftsuniversität Wien, November 2018.

178. Lecture on the “Principle Purpose Test and the Alta Energy Judgment of the Canadian Tax Court” (together with Guglielmo Maisto), IFA Milano, November 2018.

179. Lecture on the “CC(C)TB and the Digital Permanent Establishment” at Georgetown University, Washington D.C., December 2018.

180. Two day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, December 2018.

181. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2019.

182. Lecture at the University of Luxembourg on “CFC-Legislation and Art.7 and 8 ATAD”, Luxembourg, February 2019.

183. Seminar at the Malta Institute of Taxation on “CFC-Legislation”, Malta, February 2019

184. Lecture at the Global Henkel Tax Campus on “Taxation of Employees, Entertainers and Sportspersons in Tax Treaty Law”, (together with Alexandra Miladinovic), Vienna, February 2019.

185. National Reporter for Germany at the “Tax Treaty around the Globe Conference”, Lectures on “Income of a Soccer Referee” and “Companies organizing Concerts”, Wirtschaftsuniversität Wien, May 2019.

186. Lectures at the University of St. Gallen at NYU on “The OECD Model Convention”, “EU tax law”, “Comparative Fiscal Federalism: EU and the US” and “Tax planning” during the Summer Course in International Taxation, May/June 2019.

187. Lecture on “Art. 10 par 2 and Art. 11 par 2 OECD Model Convention: Direct Applicability, Refund and the Competence of Competent Authorities to Settle the Mode of Application” (together with Iona Rosca) at WU Vienna, June 2019.

188. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2019.

189. Panelist at the WU LL.M. Reception at the IFA congress on “Fundamental Tax Reform: Realising the Dream”, London, United Kingdom, September 2019.

190. Lecture at the LL.M. Program International Taxation at WU Vienna on “Article 24 OECD MC: Non-Discrimination”, October 2019.

191. Lecture on “Dispute Resolution Mechanisms”, Austrian IFA Branch, Vienna, October 2019.

192. Panelist at the Inaugural Lecture of Professor Walter Hellerstein, Wirtschaftsuniversität Wien, November 2019.

193. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxation,” Presentation of the Cases, C-480/17 (Montag), C-685/16 (EV) and C-135/17 (X-GmbH), Wirtschaftsuniversität Wien, November 2019.

194. Two day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, December 2019.

195. Lecture on “The new Art. 3(2) OECD Model Tax Convention”, Interdisciplinary Conference Tax Treaty Interpretation after BEPS, Max Planck Institute for Tax Law and Public Finance and Tax Policy Center of the University of Lausanne, Lausanne (Switzerland), December 2019.

196. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2020.

197. Panel Chair at the Guest Lecture of Eivind Furuseth on “The Use of Tax Incentives to Promote the Change to a Green Economy”, Wirtschaftsuniversität Wien, December 2023.

198. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxation,” Presentation of the Cases C-258/22 (H-Lebensversicherung) and C-537/20 (L-Fund), Wirtschaftsuniversität Wien, December 2023.

199. Lecture at the University of Milan (Italy) / OECD Conference “Revisiting Article 21 (Other Income ) of the OECD Model Convention” on “Business income versus other income”, November 2023.

200. Two-day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, November 2023.

201. Two-day Lecture on “GLOBE / Pillar 2” at the LL.M. Program International Taxation at WU Vienna, October 2023.

202. Panel Chair of Seminar G (Non-Discrimination) at the IFA congress in Cancun, Mexico, October 2023.

203. Panelist at the WU Seminar at the IFA congress in Cancun on “The future of Digital Sales Taxes”, Cancun, Mexico, October 2023.

204. Discussant, “Tax Treaty Case Studies on the Taxation of Capital Gains from Indirect Transfer of Shares”, University of Heidelberg, IFA Rhein Main Neckar, October 2023 (online).

205. Panel Chair, “International Developments in Tax Compliance“, Wirtschaftsuniversität Wien, September 2023.

206. Lecture on “The Parent-Subsidiary Directive”, CEE Summer School Wirtschaftsuniversität Wien, July 2023.

207. Lecture on “The Taxation of Dividend, Interest and Royalty Payments in International Tax Law”, CEE Summer School, Wirtschaftsuniversität Wien, July 2023

208. Two-day Lecture on “Tax Treaties – Case Studies and Specific Interpretation Issues” at the LL.M. Program International Taxation at WU Vienna, June 2023.

209. Lecture on “Domestic General Anti-Avoidance Rules (GAARs) and their impact on Tax Treaties” (together with Valentina Emanuele), Wirtschaftsuniversität Wien, June 2023.

210. Lecture on “The ability-to-pay principle in European Tax Law”, Wolfgang Gassner Gedächtnisvorlesung, Wirtschaftsuniversität Wien, April 2023.

211. Moderator on “Alternatives to Pillar 1”, Global Tax Seminar, Wirtschaftsuniversität Wien, April 2023 (online).

212. National Reporter for Germany at the “Tax Treaty around the Globe Conference 2023”, Lectures on “Taxation of a Truck Driver” and “A Triangular Case”, Wirtschaftsuniversität Wien, April 2023.

213. Panelist at the 2023 Court of Justice of the European Union: Recent VAT Case Law Conference, Wirtschaftsuniversität Wien, January 2021.

214. Lectures on “Structure of Double Tax Treaties” (together with Matthias Hofstätter) and “Interpretation and Application of Double Tax Treaties” (together with Andreas Ullmann), Akademie der Steuerberater und Wirtschaftsprüfer Vienna, January 2023.

215. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2023.

216. Four-day lecture on “International Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, December 2022.

217. Two-day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, December 2022.

218. Lecture on “Income from Employment” at the LL.M. Program International Taxation at WU Vienna, November 2022.

219. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxation,” Presentation of the Cases C-572/20 (ACC Silicones Ltd), C-431/21 (Finanzamt Bremen) and C-258/22 (H-Lebensversicherung), Wirtschaftsuniversität Wien, November 2022.

220. Panelist at the Transfer Pricing Symposium on Business Restructuring, Wirtschaftsuniversität Wien, October 2022.

221. Lecture on the “EU Draft Directives regarding the Fight against the Misuse of Shell Entities for Improper Tax Purposes and regarding the Debt Equity Bias Reduction Allowance” at Chamber of Tax Advisors and Certified Public Account Accountants Vienna, October 2022.

222. Four-day lecture on “Introduction to Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, September 2022.

223. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2022.

224. Lecture on “The Relation Between Article 17 of the OECD Model Convention and the other Distributive Rules of the OECD and the UN Model Conventions” (together with Monique Malan), Wirtschaftsuniversität Wien, June 2022.

225. Lecture on “The Relation between Article 20 of the OECD and UN Models and the (other?) Distributive Rules of the OECD and UN Models (together with Rainer Borns), Wirtschaftsuniversität Wien, June 2022.

226. Moderator at the IFA Austria event on “The Austrian Tax Treaty Policy”, Vienna, May 2022.

227. Lecture on “Trends and developments on CJEU case law on fundamental freedoms in tax matters in relation to third countries” at the Doctorate Seminar on European Tax Law, Wirtschaftsuniversität Wien, February 2022.

228. Panelist at the 2022 Global Transfer Pricing Conference, Wirtschaftsuniversität Wien, February 2022 (online).

229. Panelist at the 2022 Court of Justice of the European Union: Recent VAT Case Law Conference, Wirtschaftsuniversität Wien, January 2022 (online).

230. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2022 (online).

231. Lecture on “Non-discrimination” at the LL.M. Program International Taxation at WU Vienna, December 2021.

232. Four-day lecture on “International Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, December 2021 (online).

233. Two-day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, November 2021.

234. National Reporter for Germany on “Recent and Pending Cases at the ECJ on Direct Taxation,” Presentation of the Cases, C-620/19 (J&S Service UG), C-572/20 (ACC Silicones Ltd) and C-431/21 (Finanzamt Bremen), Wirtschaftsuniversität Wien, November 2021.

235. Lecture on “Tax Treaties Current and Future” at a Wolters Kluwer Webinar, October 2021 (online).

236. Four-day lecture on “Introduction to Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, September 2021.

237. Lectures on “Double Taxation Relief” and “Non-discrimination” at the University of Leiden (Netherlands) during the Summer Course in International Taxation, July 2021 (online).

238. Lecture on “Tax Treaty Developments” at the LL.M. Program International Taxation at WU Vienna, June 2021 (online).

239. Lecture on “Tax Treaties – Case Studies and Specific Interpretation Issues” at the LL.M. Program International Taxation at WU Vienna, June 2021 (online).

240. Lecture on “The Method Article and Unilateral Measures to Avoid Double Taxation” (together with Joy Waguru Ndubai), Wirtschaftsuniversität Wien, June 2020.

241. Lecture on “Income from Employment” at the LL.M. Program International Taxation at WU Vienna, June 2021 (online).

242. Lecture on “CFC-legislation and tax treaties” at the Instituto Brasileiro Direito Tributário (IBDT) Professional Master Program, São Paulo (Brazil), May 2021 (online).

243. National Reporter for Germany at the “Tax Treaty around the Globe Conference 2021”, Lectures on “Taxation of a Severance Payment” and “A Serious Penalty in the sense of the Arbitration Convention”, Wirtschaftsuniversität Wien, May 2021 (online).

244. Lecture at CFE Webinar Key EU Tax Law Developments for Tax Advisers on “The Lexel AB-Case”, April 2021 (online).

245. Lecture on “The EU Dispute Resolution Directive: Beyond DT(C)?” (together with Georg Kofler) at the University of Luxembourg, March 2021 (online).

246. Lecture at the Levin College of Law, University of Florida on “EU State Aid Rules”, USA, March 2021 (online).

247. Panelist at 2021 Global Transfer Pricing Conference, Wirtschaftsuniversität Wien, February 2021 (online).

248. Lecture at the Levin College of Law, University of Florida on “EU Directives”, USA, January 2021 (online).

249. Adjunct Professor Georgetown University, 1 Credit Course on “European Tax Law”, USA, January 2021 (online).

250. Three-day lecture on “International Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, December 2020.

251. Two-day lecture at the master program of the University of Luxembourg on “Non-Discrimination”, “Exemption and Credit Method“ and the “Multilateral Instrument”, Luxembourg, December 2020 (online).

252. Four-day lecture on “Introduction to Tax Law” at the LL.M. program Digitalization and Tax Law, Executive Academy, Wirtschaftsuniversität Wien, October 2020.

253. Lectures at the University of Leiden (Netherlands) on “Double Taxation Relief” and “Non-discrimination” during the Summer Course in International Taxation, July 2020 (online).

254. Lecture on “Tax Treaty Application Beyond the Scope of Art. 2 of the OECD MC 1092 and 2017: The Scope of the Mutual Agreement, Non-Discrimination and Mutual Assistance Clauses” (together with Gabriela Capristano Cardoso and Xiangdan Luo), Wirtschaftsuniversität Wien, June 2020.

255. Panelist at 2020 Global Transfer Pricing Conference, Wirtschaftsuniversität Wien, February 2020.

256. Lectures on “Structure of Double Tax Treaties” (together with Matthias Hofstätter) and “Interpretation and Application of Double Tax Treaties” (together with Andreas Ullmann), Akademie der Steuerberater und Wirtschaftsprüfer Vienna, January 2020.

 

II. Conferences/ Special Lectures organized and moderated at the University of Luxembourg

1. Double Burdens within the European Union, 10 speakers, April 2010.

2. Exchange of Information and Bank Secrecy, 12 speakers, November 2010.

3. Investing in Luxembourg: The Tax Perspective, 3 speakers, December 2010.

4. The Common Consolidated Corporate Tax Base, 3 speakers, May 2011.

5. State Aid and Tax Law, 13 speakers, November 2011.

6. The latest developments in EU Tax Law, Prof. Dr. Koen Lenaerts, November 2011.

7. Profit Attribution to Permanent Establishments: The new Authorized OECD-Approach, 4 speakers, June 2012.

8. The Commission’s Proposal for a Financial Transaction Tax, 4 speakers, December 2012.

9. Applying the OECD Partnership Report, Prof. Dr. Helmut Loukota, March 2013.

10. Taxation of Cross-Border Pensions, 7 speakers, April 2013.

11. Basics for BEPS: How to tax International Business Income, Prof. Dr. Dr. h.c. Wolfgang Schön, May 2013.

12. European Tax Law Classics, 19 speakers, January 2014.

13. A one-time Capital Level, Professor Daniel Shaviro and three panelists, May 2014.