Liber Amicorum Sven-Olof Lodin

by Andersson, Krister

• ISBN13: 9789041198501
• ISBN10: 9041198504
• Format: Hardcover
• Copyright: 2001-10-01
• Publisher: Kluwer Law Intl

Summary

In the field of international tax law, only a handful of scholars have had what it takes to actually affect policy. In recent decades (he is 65 on August 8, 2001), Sven-Olof Lodin is clearly among that distinct group. The influence of his work in the academic and business worlds has echoed far beyond his native Sweden (where he is honoured as one of the principal architects of the major tax reform of 1990) To The global context, where his great contribution has been signally recognized by his election in 1998 as the first Nordic president of the International Fiscal Association. He was a founding member of the Nordic Tax Research Council, which has done so much to ensure cooperation in tax matters between the Nordic countries. As a delegate of the Federation of Swedish Industries, he has participated in working groups at the European level and presented models of corporate taxation that are visible in EU tax policy. His colleagues and friends respect him not only for his notable achievements but also For The strong sense of justice that characterises his radical proposals for reorientation of the tax system. In this festschrift, 25 tax law scholars from all over the world confront some of the problems that have preoccupied Lodin -- cross-border income flows, tax treaties versus national codes, EC law versus national law, VAT, e-commerce income, and much more. Anyone, legal or business or academic, concerned with international taxation will benefit substantially from these insightful essays.

Table of Contents

A Tribute to Sven-Olof Lodin	9	(2)
Taxing Cross--Border Dividends and Tax Neutrality: Recent Finnish Developments	11	(10)
Edward Andersson
Financial Markets and Tax Competition	21	(19)
Krister Andersson
Johan Fall
Marketing Contributions and Other Forms of Contributions Between Swedish and Foreign Group Companies	40	(15)
Richard Arvidsson
Arbitration in International Tax Matters: Some Structural Issues	55	(9)
Hugh J. Ault
A Tale of Two Taxes: The Interaction Between Treaty and Unilateral Relief	64	(10)
John F. Avery Jones
EC Tax Law in the Case Law of the Swedish Supreme Administrative Court	74	(12)
Sture Bergstrom
Capital Gains -- An Insoluble Problem for Taxation?	86	(18)
Malcolm Gammie
Corporate Taxation: Some Reflections From a Swedish Perspective	104	(15)
Goran Grosskopf
Passing the Torch on Transfer Pricing	119	(13)
Joseph H. Guttentag
New Swedish Tax Rules for Foreign Experts	132	(13)
Gustaf Lindencrona
Exemption or Credit of Tax: What is Sweden's Preference?	145	(13)
Nils Mattsson
Who is a Taxable Person to VAT?	158	(15)
Peter Melz
Polycentry in the Sources of Tax Law	173	(14)
Aage Michelsen
Fiscal Interest and Taxpayers' Rights	187	(11)
Leif Muten
Tax Systems in the New Millennium	198	(13)
Jeffrey Owens
Fractional Taxation of Multi-State Income of EU Resident Individuals -- A Proposal	211	(11)
Kees van Raad
The EU VAT System -- Time for a Change?	222	(15)
Gunnar Rabe
The Impact of EC Law on Inheritance and Gift Taxation	237	(15)
Christer Silfverberg
Taxing Companies by Reason of Nationality and/or Place of Management: What Says the ECJ?	252	(7)
Kristina Stahl
Can Information Exchange be Effective in Taxing Cross-Border Income Flows?	259	(10)
Vito Tanzi
Howell H. Zee
Tax Competition and the Welfare State: Time to Surrender or to Reconsider	269	(14)
Kari S. Tikka
Reflections on Detemining the Source of E-Commerce Income Characterized as Income From the Provision of Services	283	(8)
David R. Tillinghast
Janus with Two Faces, or the Many Faces of Taxation	291	(15)
Frans J. Vanistendael
Tax Aspects of Migration	306	(12)
Bertil Wiman
Interpretative Mutual Agreements From a Norwegian Perspective: The Heerema Case of 1992 Revisited	318	(11)
Frederik Zimmer
A List of Sven-Olof Lodin's Works	329	(10)
Tabula Gratulatoria	339