The efforts to counter tax avoidance and tax abuse behavior have increased significantly in
recent years. The OECD's project on Base Erosion and Profit Shifting (BEPS) in particular led
to the addition of anti-abuse provisions to numerous domestic tax systems and double taxation
agreements. Alongside very broad and generally phrased regulations (general anti-abuse rules -
GAARs) there are provisions that are more targeted (specific anti-abuse rules - SAARs) with
the aim of identifying and preventing abusive tax behaviour on the basis of objective criteria.
In addition states and international organizations are increasingly relying on non-legally
binding instruments to curb tax avoidance. These developments have thus led to a patchwork of
provisions in domestic as well as in international law whose interaction with each other is
very intricate but has hardly been researched thus far. In addition many of those rules also
pose complex challenges in relation to EU law and corresponding case law of the Court of
Justice of the EU. With the Anti-Tax Avoidance Directive the EU has established a legal basis
that obligated Member States to incorporate numerous (general and specific) anti-abuse
provisions into their domestic tax legislation that were in part formerly unknown to their
legal systems. This volume is dedicated to contribute to the academic analysis of all of these
issues. Against this background the topic "Anti-Abuse Rules in International Tax Law and
their Interactions" was chosen as the general topic for the master's theses of the part-time
2023-25 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna
University of Economics and Business). The book is divided into three parts. The contributions
of the first part deal with questions of the Interaction of domestic anti-abuse measures with
anti-abuse rules to be found in double taxation agreements and also analyse these questions
from an EU law perspective. In the second part the contributions delve into the intricate
interactions of anti-abuse and other rules in double taxation agreements and again incorporate
the EU law angle on the challenges identified. The third part of the book is dedicated to
anti-abuse rules and principles under EU law and their interaction.
