References

• 2005THE PRINCIPLE OF SYSTEMIC INTEGRATION AND ARTICLE 31(3)(C) OF THE VIENNA CONVENTION599 cited
• 2020Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint72 cited
• 2014Qualification of Taxable Entities and Treaty Protection37 cited
• 2022Tax Treaty Obstacles in Implementing the Pillar Two Global Minimum Tax Rules and a Possible Solution for Eliminating the Various Challenges37 cited
• 2018Dual Residence of Companies under Tax Treaties37 cited
• 2019The OECD Public Consultation Document “Global Anti-Base Erosion (GloBE) Proposal – Pillar Two”: An Assessment30 cited
• 2022On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines25 cited
• 2020The Virus in the ALP21 cited
• 2022An Investigation into the Interaction of CFC Rules and the OECD Pillar Two Global Minimum Tax13 cited
• 2021International Investment Agreements and the International Tax System: The Potential of Complementarity and Harmonious Interpretation12 cited
• 2021Interpretation of Tax Treaties and the Decisions of Foreign Tax Courts as a “Subsequent Practice” under Articles 31 and 32 of the Vienna Convention on the Law of Treaties (1969)12 cited

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