Report 2012 – 2014 - Max-Planck-Institut für Steuerrecht und

Transcription

Report 2012 – 2014
Max Planck Institute for Tax Law and Public Finance
Max-Planck-Institut für Steuerrecht und Öﬀentliche Finanzen
Munich 2015
Activity Report 2012 – 2014
Contents
Preface5
Department of Business and Tax Law
8
A
Research in Business and Tax Law
9
I
II
III
IV V
VI
VII
VIII
Who we are
Major Projects
1. Debt and Equity in Corporate and Tax Law
2. The Treatment of Partnerships in Private Law, Accounting and Tax Law
3. International Allocation of Taxing Rights in the Age of “Base Erosion and Profit Shifting”
Conferences and Lectures Series 1. Lecture Series 2. Conferences Guest Researchers and Co-operations Tax Law
1. Basic Issues in Tax Law
2. German and Comparative Business Taxation
3. Value Added Tax 4. European Tax Law
5. International Taxation 6. Foreign Tax Law Business Law 1. Financial Accounting 2. Capital Markets Law 3. Partnership Law
4. Corporate Law
General Private Law
1. General Aspects
2. Contract Law
3. Damage Claims, Compensation and Unjust Enrichment
4. Civil Law of Succession 5. Various Comparative Pieces
European Monetary Union and European Banking Law
9
22
22
23
25
28
28
29
30
31
31
34
36
37
44
49
51
51
52
55
55
59
59
60
61
63
65
65
B Publications, Lectures, Teaching, and Awards
68
I
II III IV 68
85
94
94
Publications
Lectures at Conferences or Seminars
Editorial Services
Activities and Memberships
V
VI
VII Teaching
Awards and Prizes
Habilitation, Ph.D. and Master’s Theses
1. Habilitation Theses
2. Ph.D. Theses
3. Master’s Theses C Events, Conventions, and Committees
I
II III
Events of the Department
Participation at Conferences, Congresses, and Conventions
Participation on Committees
97
100
101
101
101
103
104
104
110
119
Department of Public Economics
126
A
Research in Public Economics
127
I
II III IV V
VI
Who we are 1. Ph.D. Students
2. Senior Research Fellows
Research Conferences and Internal Workshops Understanding Taxation and Tax Compliance
1. Tax Compliance
2. Tax Incidence 3. Optimal Taxation
International Public Finance
1. Tax Competition and Tax Havens
2. International Public Finance of Climate Policy
3. Souvereign Debt and the Eurozone
Political Economy of Distribution and Conflict
1. Conflict Theory
2. Electoral Competition
3. Intergovernmental Bargaining
4. Property Rights Allocation and its Effects on Growth and Development
Perspectives for the Future
B Publications, Lectures, Teaching, and Awards
I
II
III
IV
V
VI
Publications Lectures at Conferences or Seminars
Editorial Services
Activities and Memberships
Teaching
Awards and Prizes
128
128
136
140
148
149
156
159
163
163
167
172
174
175
180
181
183
185
187
187
198
214
214
217
218
VII
Habilitation and Ph.D. Projects
1. Habilitation Theses 2. Ph.D. Theses
CEvents, Conventions, and Committees
I
II III
Events of the Department
Participation at Conferences, Congresses, and Conventions
Participation on Committees
219
219
219
220
220
227
233
Services
236
Administration
237
IT Services
240
Press and Media Relations
243
Library
245
Scientific Advisory Board 255
Board of Trustees
257
Staff of the Max Planck Institute for Tax Law and Public Finance, January 2015.
4

Preface
It is with great pleasure that we present
this activity report of the Max Planck
Institute for Tax Law and Public Finance
for the period of 2012–2014. The report
covers a time interval which marks the
second, third and fourth year of the Institute’s existence in its still young history.
In the first report of the Institute we
briefly described the foundation period
and the institutional transition that had
to be mastered in 2010–2011. The report
for 2012–2014 can document a period of
development and consolidated work in
which the Institute could pursue ‘business as usual’, as far as such a term is
appropriate and does not pose a contradiction in terms with what an MPI does.
The MPI is an institution that, in essence,
consists of young scholars who are energetic, very mobile, highly motivated, innovative and well trained for their search
for the yet unknown, and who are eager
to encounter the challenges and excitements brought about by the opportunity
to pursue basic research.
The Institute consists of two lively research units: the Department of Business and Tax Law and the Department of
Public Economics. It unites legal scholars
and economists within one institutional
framework. Researchers from different
disciplines speak different languages,
have to follow different scientific tradi-
tions, and also speak to different communities. Young scholars have to qualify
for their careers. For this purpose they
have to acquire credits in a “currency”
appreciated by their respective peer
group. This requires them to excel with
their own methods and within their own
discipline. However, an interdisciplinary
environment can offer a lot for them.
The many topics of joint interest and discussion, in particular in matters related
to tax, led to fruitful interdisciplinary exchange. This, in turn, stimulated research
projects in the respective disciplines.
To further facilitate such intellectual
encounters, a number of Institute-wide
activities were implemented. The two
departments went on a joint two-day
retreat in this period, and also used
the Institute facilities for regular similar
events giving opportunities for mutual
presentations of recent research and ongoing projects. A joint lecture series and
joint or combined conference activities
also contributed to this interaction.
An efficient administration, chaired by
Hendrik Wanger, an excellent library,
well managed and maintained under
the guidance of Peter Weber, and an IT
Department that coped successfully with
many challenges, led by Klaus Herfurtner, were the most valuable resources
from inside the Institute which research-
Preface
5
ers could draw on. Moreover, our gratitude goes to our extremely efficient and
helpful personal assistants Gabriele Auer
and Athina Grigoriadou as well as to our
PR-officer Christa Manta for her careful
work on our outreach – website, newsletter, press coverage and (last but not
least) this activity report.
Scholars also tremendously benefited
from interaction within the Max Planck
Society. The society provides funding
and essential resources for research, but
it also provides a close family network
of institutes, with an opportunity for
interaction across the borders of individual Max Planck Institutes. Of similar
importance and positive effect were our
academic partnerships in the Munich
Kai A. Konrad
6

area, in particular with Ludwig-Maximilians-Universität in Munich (LMU),
which is quintessential for the recruiting and the educational training of the
young scholars who are one of the key
resources of the Institute. The Scientific
Advisory Board of the Institute, chaired
by Robin Boadway, devoted time and energy to look at our work from a genuinely
interested perspective and to provide
generous advice. Three meetings with
the Board of Trustees, composed of highlevel representatives of major German
and European institutions, offered reflections on our work and contributed to its
public outreach.
Munich, May 2015
Wolfgang Schön
Scientific Staff of the Max Planck Institute for Tax Law and Public Finance gathering at
the Institute’s Staff Retreat in Kreuth, Bavaria, 23–24 September 2013.
Preface
7
Back row (left to right): Stepan Bykov, Martina Sunde, Erik Röder, Leopoldo Parada, Šime
Jozipović, Guillaume Braidi, Stefan Kreutzer, Bernd Fluck, Angelika Meindl-Ringler, Gabriele Auer,
Marta Oliveros Castelon, Alexander Hellgardt, Elizabeth Gil García, Jan Lukas Rausch,
Front row (left to right): Toshiko Miyamoto, Christine Osterloh-Konrad, Dina Lijic, Laura Allevi,
Wolfgang Schön, Caroline Heber, Benedikt Lucas, Vera Gentner, April 2015.
8
A Research in Business and Tax Law
This activity report describes the developments in and the scientific achievements of the Department of Business
and Tax Law in the three years from 2012
to 2014. An introductory part provides
information on the human resources of
the Department. This includes brief biographies of the members of the Department and an overview of their research
visits during the reporting period.
The following parts report the main research output of the Institute in the areas of taxation law, accounting and business law, and general private law. These
chapters refer to the content of the work
being performed by members of the Department, i.e. the director and the senior
research fellows (post-doc fellows), junior research fellows (doctoral students)
as well as long-term guest researchers
during the reporting period.
The report is followed by a listing of
publications, presentations, committee
work and other documented scientific
activities and outreach. The list of publications includes all books, articles and
notes which were published or which
were written by the director, the senior
research fellows and the junior research
fellows while they were employed at the
Institute. Publications by guest researchers have only been included when a substantial part of the underlying work was
performed during their stay at the Insti-
tute. Doctoral and post-doctoral theses
are listed both according to when they
were accepted by the respective faculty
(in a separate list) and when they were
published as a book (in the general list of
publications). Other activities (presentations, conference participations, committee work) are included if they were pursued while the respective persons held a
position at the Institute.
I
Who we are
The Department of Business and Tax Law
has a human resources structure which
is typical for units in the human sciences
section of the Max Planck Society. The
Department consists of a group of junior
research fellows (doctoral students), a
group of senior research fellows (postdoctoral researchers, Habilitanden), the
director of the Department and both
short-term and long-term guests. The
list of guests also includes researchers
whose term at the Institute was sponsored by third parties (German and foreign research foundations, governmental programs etc.).
The group of doctoral students includes
both researchers from Germany and
abroad. The majority of doctoral students is supervised by the director of
the Institute (in his capacity as an honorary professor at Ludwig-Maximilians-
9
Universität München – LMU Munich). A
substantial group of doctoral students
is supervised by other professors inside
and outside Germany. This leads to a
sound balance and coherence on the
one hand and a lively interaction on the
other hand within the group of doctoral
students. Regular events like brown-bag
lunches and reading rounds contribute
to the internal academic exchange between junior and senior researchers at
the Institute. Doctoral students are encouraged and (financially) supported to
participate in national and international
conferences and to visit foreign academic institutions.
The group of senior research fellows consists of post-doctoral researchers (Habilitanden) who have decided to build an
academic career. Currently, the Department has filled all five available positions
Senior research fellows (Habilitanden)
of the Department in May 2015 (left to
right): Alexander Hellgardt, Christine
Osterloh-Konrad, Birke Häcker, Caroline
Heber, Erik Röder.
10
for senior research fellows. They cover
a broad range of subjects and bring in a
huge variety of topics and methodology,
including general civil law, corporate law,
capital markets law, accounting law and
tax law. Three of these research fellows
are supervised by the director of the
Institute (Alexander Hellgardt, Christine
Osterloh-Konrad, Erik Röder) while two
are supervised by outside institutions
(Birke Häcker, Caroline Heber).
The group of guest researchers spans
a wide range of countries within and
outside Europe, including both highlevel senior researchers of international
reputation and junior (doctoral) students. While the majority of visitors
stays at the Institute for three weeks to
three months, we also welcome guest
researchers for just a few days or a full
year.
Birke Häcker
Caroline Heber
Alexander Hellgardt
Birke Häcker has been a senior research fellow at the
Institute since the end of 2011. She is a fully qualified
German lawyer and also holds an English law degree
(M.A.) as well as a doctorate (D.Phil.) from the University of Oxford. Birke works mainly on private law topics,
with a special focus on the comparative and historical
perspectives. In 2013, she co-edited a collection of essays on “Restitution of Overpaid Tax”. Birke maintains
strong links with the UK, where she is a Fellow of All
Souls College, Oxford, and was recently elected an
Academic Member of the Chancery Bar Association.
Caroline Heber joined the Institute in 2013. Before
that, she was a research fellow at the Ross Parsons
Centre of the University of Sydney and the Tax Department of the University of Graz. She holds a Ph.D. in Law
from the University of Graz and a Master of Taxation
from the University of Sydney. Her doctoral thesis on
“Transactions between Shareholders and their Companies within the Scope of VAT” was awarded several
prizes, e.g. the Dr. Maria Schaumayer Preis 2013. Her
research interests are on European and international
taxation with a particular emphasis on European tax
harmonisation. Alexander Hellgardt studied Law and Philosophy at
Tuebingen (1st State Exam 2002; B.A. 2003), Hamburg
(Ph.D., 2008) and Harvard (LL.M., 2009) and completed the practical legal training in Hamburg (2nd State
Exam, 2008). He worked as a research associate at the
Max Planck Institute for Comparative and International Private Law in Hamburg (2003-08). Since 2009 he
has been a senior research fellow at the Institute and
Lecturer-in-Law at the Ludwig-Maximilians-Universität
München. His research interests are private law and
legal theory, corporate law and securities regulation.
11
Christine Osterloh-Konrad
Erik Röder
12
Christine Osterloh-Konrad was already a research associate at Max Planck from 2002 to 2004, when she
wrote her Ph.D. thesis on informational duties in
private law. Her thesis was awarded the Otto Hahn
Medal and the Law Faculty Award of the Ludwig-Maximilians-Universität in Munich. After having gained
some practical experience, she joined the Institute
again in 2008 as a senior research fellow. She works
both in the fields of private and tax law, her research
focussing primarily on matters of tax avoidance, on
corporate law and accounting, and on inheritance law.
Erik Röder joined Max Planck in 2008 as a part-time
research assistant. Since 2011, after passing the Second State Exam in Law, he has been a senior research
fellow. Before joining the Institute, he was a research
assistant at the University of Bayreuth. He holds a
Ph.D. in Law from the University of Bayreuth and a
maîtrise en droit from the University of Montesquieu
– Bordeaux IV. His doctoral thesis on the system of
loss compensation under German tax law was awarded the Albert-Hensel-Prize 2010 of the “Deutsche
Steuerjuristische Gesellschaft” (German Tax Law Association). His research interests are in Private Law,
Partnership and Corporate Law as well as German,
European and international tax law.
Anastasios Andrianesis
Chiara Balbinot
Ferdinand Blezinger
Anastasios Andrianesis was a doctoral researcher
and scholarship holder at the Institute from 2010 to
2014. Before that, he studied Law in Athens, Greece
and holds two master degrees in Law from the University of Athens and from the Ludwig-MaximiliansUniversität in Munich (LMU). Since 2008 he has been
an attorney-at-law in Athens. He published several
legal essays in Greek and German law journals in
the field of company and capital markets law and a
monograph about the duties of the board of directors
of a public company in the case of a hostile takeover
bid. He taught for three semesters between 2010 and
2013 German civil law at the LL.M. Program of LMU
Munich. He also holds a piano diploma.
Chiara Balbinot was a research associate at the Institute from 2012 to 2014. During this time, she wrote
her thesis on “Tax Neutrality and State Aid Law” (Ph.D.
program, Ludwig-Maximilians-Universität München)
and published articles on national and international
tax law. She holds a degree in Law from the University of Passau (First State Examination) and clerked
at Kammergericht Berlin (Second State Examination).
She focuses on national and international tax law and
European State Aid Law.
Ferdinand Blezinger joined the Institute in 2010 as a
student assistant and became a research associate in
2013. From 2007 to 2013 he studied Law at LudwigsMaximilians-Universität in Munich, specialising in
corporate law, capital markets law and insolvency law.
In 2014 he intermitted his research project at the Institute to pursue studies for an LL.M. at the University
of Cambridge. His research interests lie in the field of
corporate law and the law of partnerships.
13
Sara Dietz studied Law and International Relations
at Ludwig-Maximilians-Universität in Munich and at
Oxford University. She is a scholar of the Maximilianeum Foundation and received the Alumni Prize for
outstanding achievements in European Union law and
public international law in 2009. After practical insights through her work at the European Central Bank,
she joined the Max Planck Institute at the end of 2014
and writes her doctoral thesis on the independence of
the ECB and judicial control.
Andreas Eggert
Andreas Eggert was a research associate at the Institute from 2011 to 2013. Currently, he works as a lawyer
at the tax practice group of Hogan Lovells International
LLP in Munich. He advises companies in all areas of tax
law. The main focus of his work lies on the tax structuring of transactions, the representation of clients in tax
proceedings as well as the advice on tax compliance
issues. He regularly publishes in tax journals.
Mauritz von Einem was a research associate at the Institute from 2011 to 2013. Before, he studied Law and
Business Administration in Goettingen and Geneva.
He writes his Ph.D. thesis on “IP Migration – Taxation
of IP Holding Companies”.
Mauritz von Einem
14
Kilian Eßwein
Kilian Eßwein studied Law in Regensburg and Sheffield,
UK and specialised in company law and bankruptcy
law. His doctoral thesis entitled “Privatautonome
Gestaltung der Vorstandshaftung” focused on the liability of directors of stock corporations (Aktiengesellschaften) under German stock corporation law (AktG).
He completed his Ph.D. at the Institute in 2014 and is
currently working for a law firm in Munich.
Deborah Fries joined the Institute in 2014 after having
finished her legal training in Munich. She holds a Master in International Law from the Université Paris 2
Panthéon-Assas. Her research focuses on national and
international insolvency and tax law.
Deborah Fries
Andreas Gerten was a research associate at the Institute from 2007 to 2012. He holds a Ph.D. in Law from
the University of Cologne and a Master in International Taxation from New York University. His research
interests are on related party transactions with a particular emphasis on transfer pricing and European tax
harmonisation. Andreas Gerten
Mirja Hennigs
Mirja Hennigs was a Ph.D. scholarship holder at the
Institute from 2011 to 2013. She worked for the Federal Financial Supervisory Authority, Bavarian fiscal
authorities and the Bavarian Ministry of Finance. Currently, she is a guest of the Institute and employed at
the Bavarian Court of Auditors. She passed her First
and Second German State Examination in Laws and
holds a Master of European Law from the Universities
of Bielefeld and Nottingham. Her research interests
are on the effects of European Fundamental Freedoms, particularly with regard to tax administration.
15
Yasmin Holm
Šime Jozipović
Leif Klinkert
Stefan Kreutzer
16
Yasmin Holm joined the Institute in 2012. Prior to that,
she passed the second legal state exam in Munich and
worked part-time in a law firm. She pursued her legal education at the Julius Maximilians-Universität in
Würzburg and at Ludwig-Maximilians-Universität in
Munich. Her fields of interest are German and international tax law, in particular double taxation treaties
and the taxation of business profits. She also studied
history, with a focus on medieval (tax) history, at LMU
Munich.
Šime Jozipović joined the Institute in 2011 on a Ph.D.
research scholarship. He holds a Master’s degree in
Law from the University of Split and an LL.M. degree
from Ludwig-Maximilians-Universität in Munich. He
has conducted research in the field of tax law, European law, constitutional law and insolvency law. He is
currently working on his Ph.D. thesis on the influence
of EU state aid law on international tax law.
Leif Klinkert joined the Institute in 2010 as a research
associate. Before, he finished his legal studies at Ludwig-Maximilians-Universität in Munich. His doctoral
thesis discusses problems of statutory limitations on
distributions under the German HGB (Handelsgesetzbuch). For the purpose of a comparative study on
the Californian systems he spent a term as a visiting
scholar at the University of Berkeley, California. In
2013 he started his legal traineeship at the District of
Dusseldorf and will finish it by mid-2015.
Stefan Kreutzer joined the Institute in 2014. He completed his legal studies at Ludwig-Maximilians-Universität in Munich in 2014. During his studies he worked
as a student assistant for the law firm Reed Smith LLP
in Munich, mainly in the area of litigation. Currently
his research is focused on a comparative study on
non-recognition rules in the context of contributions
and distributions in partnerships for income tax purposes.
Dina Lijic
Dina Lijic studied Law at the University of Split and
Economics at the Business School ‘Minerva’. She specialised in tax law and achieved her Masters of Law
degree in 2014 by defending her thesis “Certain Issues in Croatian International Tax Law and Double Tax
Conventions”. She is researcher at the Instititute since
November 2014 and focuses on comparative business
taxation. Currently she studies in the Certificate program of the LMU Munich.
Angelika Meindl-Ringler joined the Institute in 2011.
She interrupted her stay at the Institute in 2012–2013
to obtain her LL.M. at Columbia Law School in New
York. After her return, she continued working on her
Ph.D. thesis on “Beneficial Ownership in Double Taxation Conventions”. Since then, she has also visited the
Ross Parsons Centre at the University of Sydney and
Angelika Meindl-Ringler the Centre for Business Taxation at the University of
Oxford, where she did research on the Australian and
United Kingdom aspects of her thesis. Her main research focus is on international tax law.
Bianca Mostacatto
Bianca Mostacatto has been writing her Ph.D. thesis at the Institute since December 2011. She holds
an LL.M. in Corporate Law from New York University
(2010) and a master degree in Law and Economics
from Universität Hamburg (2011). Before leaving her
home country, Brazil, in 2009, she had been a practicing lawyer for over 6 years in business-related fields
and worked in parallel for several years as an assistant
professor and lecturer at a private university in Rio de
Janeiro.
17
Marta Oliveros Castelon
Leopoldo Parada
Thomas Poschenrieder
18
Marta Oliveros Castelon is completing her Ph.D. thesis
on “International Taxation of Income from Enterprise
Services” under the supervision of Prof. Dr. Dr. h.c.
Wolfgang Schön and Prof. Luís Eduardo Schoueri, Ph.D.
She has been a research associate at the Institute since
2010. Currently, she also holds a teaching position at
the Law Faculty of Ludwig-Maximilians-Universität in
Munich. Her main fields of interest are tax law, law
and economics, and constitutional law. Before becoming a researcher in Germany, Marta acted as a lawyer
in the city of São Paulo, Brazil. She graduated from the
University of São Paulo (2008) and she holds a Master
of Laws’ degree from LMU Munich (2010).
Leopoldo Parada joined the Institute in 2013. Before,
he was research assistant at the University of Florida
Levin College of Law and practiced as tax attorney and
counsellor on U.S. international tax matters in the
United States, Brazil and Colombia. Previously, he also
practiced as tax attorney in Chile. He holds a Master
of Laws (LL.M.) in International Taxation from the University of Florida Levin College of Law and he is a Ph.D.
in Law Candidate from Universidad de Valencia, Spain.
His research interests are on international taxation.
Thomas Poschenrieder joined the Institute in 2012.
Before that, he was a research associate to Prof. Dr.
Hans-Georg Hermann at Ludwig-Maximilians-Universität in Munich. His research interests are on private
law, company law and commercial law on the one
hand and on theory and methodology of law on the
other. In both fields of interest he carries out comparative studies of English law. He also holds a Master in
Philosophy and Classical Philology and has published
on Thucydides’ Philosophy of History.
Philipp Redeker
Philipp Redeker worked at the Institute from April
2004 to May 2012. His doctoral thesis on an issue of
contract law was awarded the Ph.D. Thesis Award of the Munich University Society and the 2012 Faculty
Prize of the Law Faculty of Ludwig-Maximilians-Universität in Munich. The emphasis of his research at the
Institute was on private law as well as the taxation of
hybrid capital in a national and international context.
After leaving the Institute, he joined an international
law firm where he is currently working in the tax department.
Susanne Risch studied Law in Munich and Lausanne.
She was a research associate at the Max Planck Institute from 2010 to 2013 and wrote her dissertation on
the “UNIDROIT Convention on Substantive Rules for
Intermediated Securities”. Her fields of interest are
corporate law and equity capital market law.
Susanne Risch
Amelie Singer joined the Institute in 2012 after finishing her law degree at the Ludwig-MaximiliansUniversität in Munich. Her research interests are on
international private law and the Common European
Sales Law.
Amelie Singer
19
Christian Sternberg
Christian Sternberg joined Max Planck in 2013. Before
that, he was a research fellow at the Institute for Tax
Law of the University of Münster and the GermanDutch Research Centre for Cross-Border Taxation. He
is a Ph.D. student in Law at the University of Münster
and a Ph.D. student in Economics at the University of
Erlangen-Nuremberg. His research interests in economics are on the taxation of multinational enterprises and in law on European and international taxation
and international law.
Martina Sunde joined Max Planck in 2012 as a doctoral student. Before, she worked for several years
as lawyer and tax consultant in business law firms in
Switzerland and Germany. In her research she analyses the interactions of international Law, European
law and the national law of Germany and Switzerland
in the field of taxation.
Martina Sunde
Christine Watzinger
20
Christine Watzinger (née Komisarczyk), was a research associate at the Institute from 2012 to 2014.
She worked on her doctoral thesis “Rechtliche Probleme der Ausgestaltung von Zahlungssystemen in der
Europäischen Wirtschafts- und Währungsunion. Eine
Analyse von TARGET2” (“Legal Aspects of the Design
of Payment Systems in the European Monetary Union”) at the University of Passau. Prior to joining the
Institute, she completed her Second State Examination in Munich/Passau and studied Law (First State
Examination) at the University of Passau.
Research Visits

Ferdinand Blezinger
Cambridge University, UK, LL.M.Program, October 2014 – June 2015

Birke Häcker
Max Planck Institute for Comparative and International Private Law,
Hamburg, Research Visits, January
and May 2012; May 2014

University of São Paulo, Brazil,
Research Visit, September –
October 2013

Oxford University (UK), Research
Visits, February, March, June 2012;
March, October, December 2013;
February, March, May, June, October, December 2014




Alexander Hellgardt
Oxford University, UK, Academic
Visitor Program, April – May 2012
Leif Klinkert
Heinrich-Heine-Universität Düsseldorf, Research Visit, June –
September 2012
Angelika Meindl-Ringler
Columbia Law School, New York,
USA, LL.M.-Program, August 2012 –
June 2013
University of Sydney, Australia,
Research Visit, January – February
2014
University of São Paulo, Brazil,
Research Visit, December 2011 –
January 2012

Philipp Redeker
European Commission, Brussels,
Belgium, Internship, January –
March 2012
Erik Röder
Harvard University, USA, and
Levin College, University of Florida,
Gainesville, USA, Research Visit,
September – November 2014
Wolfgang Schön
Oxford University, UK, International
Research Fellowship, March 2013
Columbia Law School, New York,
USA, Short-Term Scholarship,
September 2014

Christine Watzinger
Harvard University, USA, Research
Visit, February – March 2014
Oxford University, UK, Research
Visit, May – June 2014
21
IIMajor Projects
In the reporting period 2012 – 2014, a
significant number of major and minor
projects were brought to a successful conclusion, while others were significantly advanced. Besides all ongoing
research projects, the Institute has also
engaged in new projects which highlight
the Department’s future research focus.
The following research activities of the
Institute deserve a particular mention
up-front:
The Debt-Equity Distinction in Tax and
Corporate Law

The Treatment of Partnerships in Private Law, Accounting and Tax Law

The Initiative of the OECD concerning
“Base Erosion and Profit Shifting”

Wolfgang Schön (ed.)
Eigenkapital und
Fremdkapital
Steuerrecht – Gesellschaftsrecht – Rechtsvergleich
Springer
876 p.
22
1. Debt and Equity in Corporate
and Tax Law
One major project of the Department
pertaining to debt and equity in company and tax law was completed in
2012/2013; the major bulk of the underlying research was already undertaken
during the previous period of reporting
(cf. Research Report 2010–2011, p. 17
ff.). This project analyses the dividing
line between capital provided by the
owners of a business and capital provided for business purposes by its creditors
from a legal and economic point of view.
The scope of this major research work is
not limited to German law and practice;
it also includes a comparison with the
framework of financing under corporate
and tax law in other states, such as Austria, Brazil, France, Greece, the Netherlands, Switzerland, United Kingdom and
the U.S. These country reports are complemented with reports on international
practice on withholding taxes, legislative
restrictions on intra-group financing and
double taxation in the light of the OECD
Model Convention.
The outcome of this work was presented
in a voluminous collection (Schön (ed.),
Eigenkapital und Fremdkapital: Steuerrecht – Gesellschaftsrecht – Rechtsvergleich – Rechtspolitik, MPI Studies in
Tax Law and Public Finance 3, SpringerScience, 2013). For the international
audience, the major findings were summarised in a concise fashion in two articles (for the short version see: Schön,
The Distinct Equity of the Debt-Equity
Distinction, 66 Bulletin for International
Taxation (2012) 490 and for the long version see: Schön et al., Debt and Equity in
Domestic and International Tax Law, British Tax Review (2014) 146).
In these publications, the authors show
that the borderline between debt and
equity is not only different with regard to
corporate law on the one hand and tax
law on the other hand. They reach the
conclusion that within the framework
of tax law it makes a difference whether
a financial instrument is characterised
as debt or equity in the context of individual income taxation (co-ownership of
business vs. loan relationship), corporate income taxation (shares vs. corporate bonds) and international taxation
(cross-border interest vs. cross-border
dividends). Against this background,
the widely acknowledged “debt bias”
of taxation law has to be regarded as an
oversimplification of the underlying economic and legal rationale for the debtequity-distinction in the respective fields
of application.
2. The Treatment of Partnerships
in Private Law, Accounting and
Tax Law
A “follow-up” project to the afore-mentioned work on debt and equity is a new
multi-year project of the Department on
the treatment of civil and commercial
partnerships under private law, accounting law and tax law respectively. As with
other previous projects (e.g. on the linkage between commercial accounting
and tax accounting or on the interaction
between tax and corporate governance)
the Department intends to employ its
expertise both in the area of private law
British Tax Review (BTR) 59/2014, No. 2,
including the article “Debt and Equity in
Domestic and International Tax Law - A
Comparative Policy Analysis”.
and of tax law to present novel insights
and legislative proposals. Currently,
there are several sub-topics which have
been addressed and are further pursued
within the Department:
At the level of civil and commercial law,
the Department has produced two major
studies on the legislative framework and
development of partnership law from a
comparative and policy perspective. Both
studies were authored by Erik Röder. In
his first paper, he examines the history
of the “limited partnership” as a legal
form for medium-sized and even large
business firms over the course of the 20th
century. While this legal form has been
successful in Germany to this day, in
other European countries and the United
States it has been far less attractive for
business founders. Until Röder’s work,
the major view was that the dominant
role of the limited partnership in Germany is due to either tax reasons or the
23
strict disclosure requirements for private
limited companies. But Röder shows that
Germany is (virtually) the only country
which allows the limited partners (Kommanditisten) to participate actively in the
management of the partnership without
being subject to full and unlimited liability for the partnership’s obligations.
This unique combination of control and
limited liability has made the German
limited partnership a multi-use device
for closely-held business organisations.
Röder, Erik. Die Kommanditgesellschaft
im Rechtsvergleich: Hintergründe der
unterschiedlichen Karriere einer Rechtsform. RabelsZ 78/2014, No. 1, 109-154.
In a second article Röder scrutinises the
currently less-than-satisfying regime of
civil law partnerships in Germany. This
is the battlefield of an unresolved conflict between the traditional concept of
the partnership as a personal contract
between the partners, accompanied by
joint ownership in the assets devoted to
the common purpose, and the emerg-
24
ing jurisprudence of the Federal Court in
Karlsruhe which recognised the full legal
capacity of the partnership in 2001 but
which was not able to introduce the necessary safeguards like a public register
or tailor-made liability rules. Against this
background, Röder puts forward a twotiered legislative proposal which offers
on the one hand a fully-registered and
disclosed variant of a civil partnership,
which is entirely capable of acting legally,
and on the other hand a non-registered
form which rolls back onto the original
understanding of the partnership as
a contract binding upon the partners
without any specific rules on separate
“ownership” of partnership assets. The
long-standing “Germanic” concept of
Gesamthand would be abandoned under these new rules.
At the level of accounting law, an ongoing
dissertation is focused on the allocation
of partnership income to the partners
(Blezinger). The starting point for this
project lies in the fact that the allocation
rules under the civil code and under the
commercial code are completely out of
sync with the business model for a modern partnership and its requirements.
Against this background, the dissertation
is meant to propose new legal rules on
profit allocation based on comparative
work and on a detailed analysis of current practice as found in partnership
agreements for different real life types
of partnerships (law firms, commercial
entities, investment vehicles etc.).
At the level of tax law, the Department
was invited by the U.S. Congress (Joint
Committee on Taxation) to contribute
to a comparative study on transparent
taxation in major industrialised countries which was meant to form a basis
for partnership tax reform in the United
States. This has resulted in a report coauthored by Christine Osterloh-Konrad
and Wolfgang Schön on partnership
taxation in Germany. This report fed into
a legislative proposal discussed in the
U.S. Congress in 2014. In this context, an
ongoing dissertation (Kreutzer) engages
in the tax consequences of the reorganisation of partnerships, in particular, the
accession of new partners, the exit of
partners, the merger and demerger of
partnerships and similar events in the
lifecycle of a partnership. While German
tax law contains very specific provisions
on these issues, the overarching concept
is still unclear from a policy perspective
(in particular the fact that some reorganisations are only possible tax-free if
they concern the enterprise as a whole
while others can be executed without
taxation of unrealised profits with regard
to single assets as well). Built on extensive comparative work (in particular with
U.S. law), the dissertation is meant to
propose a new framework for this area.
tinationals have to pay their “fair share”
and they must not shift their profits into
low tax jurisdictions. On the other hand,
countries still engage in tax competition
streamlining their national tax laws to attract business.
3. International Allocation of Taxing
Rights in the Age of “Base Erosion
and Profit Shifting”
The start of the OECD’s project on “Base
Erosion and Profit Shifting” in Winter
2012/13 enabled the Department to
exploit its resources and in particular its
previous work on international allocation of taxing rights and on international
transfer pricing for multinational companies to engage closely in the global
debate. Moreover, the Institute’s interdisciplinary focus on tax competition
came to the fore as strategic tax planning
by multinational enterprises is largely
made possible by competitive strategies
of countries trying to attract inbound investment by employing preferential tax
regimes.
The most “topical” research project of
the Department in the area of international taxation concerns the question
on how multinational enterprises can,
and should, be taxed. This question has
high priority on states’ agenda since
politicians and NGOs demand that mul-
In this context, the Institute organised
and co-organised several international
and interdisciplinary conferences and
will continue to do so. The first conference entitled “Taxing Multinationals: the
International Allocation of the Tax Base”
was held in Oxford in March 2013 and
25
Michael Devereux from the Oxford University Centre for Business Taxation
opens the Conference “Taxing Multinationals: the international Allocation of
the Tax Base” in Oxford, March 2013.
was jointly organised by the Institute and
the Oxford University Centre for Business
Taxation. On this occasion, Wolfgang
Schön laid out the basic challenges of the
BEPS project, in particular with regard to
the dividing line between a major shift of
taxing rights between source countries
and residence countries on the one hand
and a targeted response to “aggressive”
behaviour on the other hand. Further
conclusions could be presented in the
following weeks at conferences organised by the University of Luxembourg,
the Federal Ministry of Finance in Berlin
and the Confederation of Swedish Enterprise in Stockholm. A specific highlight
in this context was the opportunity to
brief Federal Chancellor Merkel on these
topics in the run-up to the G8 Summit in
Lough Erne in June 2013. These matters were also addressed in
research work undertaken by a visiting
professor (Ault) looking at key pressure
26
points that are involved in corporations
reducing their tax rate. The author highlighted two facts: First, the observer’s attention is drawn to the shift of the OECD’s
policy aim. In the past the OECD has concentrated on developing solutions to the
problem of double taxation. But now, the
OECD is mainly concentrating on double
non-taxation, and thus, we run back into
issues of potential double taxation. Second, the author questions whether BEPS
problems can be solved without getting
into the more fundamental questions
of the appropriate allocation of the tax
base between residence country and
source country.
One of the most intricate problem of
international profit shifting is related
to contractual risk allocation between
different parts of a corporate group.
Major examples include “captive insurance” companies, the restructuring of
fully-fledged distributors into mere commissionaires and the work of research &
development units or production units
on a risk-free cost-plus basis. Both OECD
and major countries regard these forms
of risk-shifting to constitute a major
source of detrimental profit shifting.
From a principled point of view, this is
surprising, given the fact that “risk” is
an inherently symmetric concept so that
countries should be indifferent to the
degree of “riskiness” to which local business is exposed. This gave rise to more
research done at the Department on “international taxation of risk” which was
also informed by the work performed
by the Department of Public Economics
on taxation and risk-taking. It turned out
that three factors drive a country’s inter-
est to pull risky activities to its territory:
deficient tax rules on loss compensation,
the existence of “risk premiums”, and
the problem of “hidden intangibles”,
meaning cases where intangible value
has been created before the “shifting”
of assets or opportunities is effected so
that the actual “risk” accompanied by
these assets is smaller than reflected
in the books. This work was presented
by Schön on different occasions both
in Europe and in the United States and
Canada.
The second conference hosted by the
Institute in January 2014, co-organised
by Hugh Ault (Boston College) and Steve
Shay (Harvard Law School) and co-sponsored by the Harvard Fund for Tax and
Fiscal Research, turned to the first drafts
and further materials produced by OECD
in the area of “Base Erosion and Profit
Shifting”. During this conference, the
speakers discussed the current system
of international taxation and the actions
proposed by the OECD, and identified
possible challenges, problems, but also
solutions for an international tax system
which is fit for the 21st century. One of
the major areas of concern lies in the
under-reflected assumption of the BEPS
project that allocation of taxable profit
has to follow the “creation of value” and
its location. Given the fact that “value
creation” is not a concept used in the
formation of the current international
tax system as framed by the OECD Model
Convention and many other unilateral
and bilateral tax provisions, it deserves
further scrutiny to what extent the BEPS
project is built on reliable conceptual
ground.
This refers to a further longterm project which was embarked upon during
the reporting period. In a joint effort,
researchers from Oxford University (Michael Devereux, John Vella), University of
California at Berkeley (Alan Auerbach),
Columbia University (Michael Graetz),
the International Monetary Fund (Michael Keen) and the Max Planck Institute
(Wolfgang Schön) together with the
representative of a global law firm (Paul
Oosterhuis) are trying to analyse the
deficiencies of the current system from
first principles and to come up with a variety of proposals to remedy the existing
inefficiencies. So far this group has met
several times in Oxford, New York and
Washington to exchange and discuss preliminary papers which might result in an
overarching publication in the long run.
Besides the tax law context, the Department strongly engages in research in
the field of company law, financial accounting and the law relating to capital
markets. The Department also places
a strong emphasis on special issues in
Conference on Base Erosion and Profit
Shifting, 24–25 January 2014.
27
private law. This allows bringing together
researchers from different fields of the
law. As a result, the Department’s research projects provide a complete picture by covering various fields in the law.
III Conferences and
Lectures Series
Members of the Department frequently
speak at conferences, both on national
and international level. Besides this engagement, the Institute itself organised a
number of such events during the report
period.
1. Lecture Series
Both Departments of the Institute contribute on a regular basis to the joint lecture series which was established many
years ago. The Department of Business
and Tax Law has decided to devote every
other year a limited number of lectures
Juliane Kokott
and Wolfgang
Schön, July 2013.
28
to a common topic with the prospect of
assembling the presentations in a book
published under the auspices of the
Institute’s book series. In 2012, the Department dedicated this lecture series to
longterm developments of German tax
law. This series provided a forum specifically for “young and rising stars” of the
German and Austrian tax law community
(Marc Desens, Michael Droege, Roland
Ismer, Andreas Musil, and Tina EhrkeRabel) to elaborate their individual views
on how the future landscape of taxation would look like. The presentations
covered general issues of tax legislation
as well as specific conflicts between national tax law and the law of the European Union on the one hand and constitutional law on the other hand. Besides
this, the taxation of certain sectors of
the economy was discussed in these lectures.
The Institute hosted a similar dedicated
lectures series on the fundamentals of
European tax law in 2014. The aim of this
lecture series was to highlight the influence of primary and secondary Union
law on member states’ national tax law.
Speakers included Georg Kofler, Hanno
Kube, Juliane Kokott, Michael Lang, Alexander Rust, and Wolfgang Schön. In
their presentations, the scholars pointed
out possible future developments, and
they provided a challenging and critical
perspective on European tax law. The
topics discussed ranged from current issues in European tax law – e.g. the CJEU
jurisprudence on final losses – to the
influences of fundamental principles of
European Union law on tax legislation.
2. Conferences
In the context of BEPS, the Department
has organised several conference in
cooperation with other academic institutions which were mentioned under
chapter II. But there is more to report.
Together with the International Network
for Tax Research and the German branch
of the International Fiscal Association,
In September 2013, several members
of the Ross Parsons Centre of the University of Sydney travelled to Munich to
take part in the Munich-Sydney Conference jointly organised by the Max Planck
Institute and the University of Sydney.
This interdisciplinary conference which
convened both lawyers and economists
from research institutions in Munich and
Sydney provided magnificent opportu-
Munich-Sydney-Conference on the Law and
Economics of Taxation,
September 2013.
the Department organised a joint conference on “Intangibles and Transfer Pricing” in July 2012. The starting point of
this conference was the ongoing work of
OECD on the Transfer Pricing Guidelines
for Multinational Enterprises where the
taxation of intangibles raised an extensive debate not only among practitioners
but also in academia and – last but not
least – in political circles. Intangibles are
hard to conceptualise and even harder
to measure. They are often used by multinationals to shift their taxable profits
from a high tax jurisdiction to a low tax
jurisdiction or even a tax haven. This
interdisciplinary conference aimed at
identifying the problems associated with
taxing intangibles, analysing the OECD
project, and providing possible ways for
the future.
nity to discuss major matters of national
and international business taxation. The
conference also strengthened the cooperation between the Ross Parsons Centre
and the Max Planck Institute.
Some years ago, the Institute established
a forum for junior scholars at the post-doc
level in the field of tax law. In November
2013 it hosted its second postdoctoral European tax conference. This conference
gave several junior scholars the opportunity to present pieces of their ongoing
research work, get feedback from other
young scholars, and establish a network
among the young generation of European
tax law scholars.
29
IV Guest Researchers and
Co-operations
The Institute was delighted to welcome
high-profile visiting scholars from all over
the world in 2012, 2013, and 2014. Over
this time period, the Institute attracted
guest researchers and scholarship holders from the Asia-Pacific region (e.g.
Australia, China, Japan, South Korea,
Taiwan), the Middle East (Turkey, Iran),
South America (Brazil, Chile, Colombia),
North America (the U.S.), Africa (South
Africa, Kenya), Europe (e.g. Austria, Belgium, Croatia, Hungary, Italy, Norway,
Portugal, Spain, Switzerland, UK), and
Russia.
Over the last years, the Ross Parsons Centre of the University of Sydney and the
Guest researchers currently at the
Department include (left to right):
Toshiko Miyamoto (Japan), Guillaume
Braidi (Switzerland), Laura Allevi (Italy),
Stepan Bykov (Russia), Elizabeth Gil
García (Spain).
30
Max Planck Institute have established
a strong relationship which is built on a
similar interdisciplinary institutional layout and research agenda (including law
and economics and – in law – both commercial, corporate and tax law). Thus, in
2014 the Max Planck Institute entered
into a formal substantive co-operation
agreement with the University of Sydney.
This agreement provides researchers of
both institutions with an easy access to
research facilities of the other institution.
The Institute is proud to have strengthened its academic links also with other
major foreign research institutions.
V Tax Law
Wolfgang Schön
Erik Röder (eds.)
1. Basic Issues in Tax Law
Zukunftsfragen des
deutschen
Steuerrechts II
The Institute is engaged in research work
on major and fundamental questions of
tax law in general. These include conceptual matters, the constitutional background, the law of the European Union
and the international framework. Scholars of the Institute propose far-reaching
reforms addressing existing issues in tax
law.
a) Tax Law and Public Economics
In a keynote lecture prepared for a highlevel symposium hosted at the University
of Heidelberg in 2013, Wolfgang Schön
embarked on a venture to lay out possible inroads for findings of optimal tax
theory into the design and application
of tax legislation. Some of the major
findings of optimal tax theory – the nonobservability of individual preferences
and abilities, the pitfalls of majority voting and the problem of defining a useful social welfare function – led directly
to constitutional issues, e.g. when the
principle of democracy, the principle
of equal treatment of taxpayers or the
quantitative limits to the State’s taxing
rights are concerned. Schön proposes to
move academic work in tax law further
into an interdisciplinary direction, taking
on board not only “classic” issues like
neutralities and deadweight losses but
also more recent work which goes deep
to the heart of political decision-making
and its theoretical underpinnings.
Springer
IX + 148 p.
This presentation was followed a few
months later by another keynote speech
delivered on the occasion of a symposium on fundamentals of tax law research
hosted by the University of Düsseldorf.
Under the title “Crossing Borders in
Taxation” he put forward the proposal
to develop legal research in the area of
taxation into different dimensions: to
strengthen the interaction with other
fields of law (constitutional law, administrative law, private law), to look for truly
interdisciplinary research questions (in
particular vis-à-vis public economics) and
to deepen the historical dimension of tax
law.
b) Interpretation of Tax Law
in Germany
Judicial approaches to the interpretation of tax law in Germany include four
distinct but complementing methods
of interpretation, generally referred to
as the four canons of Savigny: an initial
approach that looks at the wording of a
provision, a broader approach that looks
31
at the wider structure of the statute, a
third approach that bases the interpretation of a section on the historical background of the provision, and the fourth
approach that seeks to elaborate upon
the function of a particular provision in
the tax law. These general approaches to
interpreting tax laws are complemented
by the application of specific doctrines
related to developing the law beyond
its textual limits. Two members of the
Institute elaborated these methods of
interpretation with respect to German
tax law (Heber, Sternberg) for a collected
volume published in 2014. The research
work points out that the traditional German interpretation methods have been
adjusted to meet the requirements of
European Union law. Moreover, it looks
at the options to employ purposive interpretation to fight tax avoidance.
c) Tax Avoidance and the Rule of Law
Good progress was made with the broadranging comparative research project on
tax planning and tax avoidance (OsterlohKonrad; cf. Research Report 2010–2011,
p. 17). On the one hand, the comparative work shows many parallels among
jurisdictions, especially concerning various attempts to formulate a satisfactory
definition of tax avoidance via concepts
such as artificiality, form as opposed to
substance, sham or lack of business purpose. However, equally widespread is the
perception that these definitions are all
more or less unsatisfactory. Particularly
unclear seems to be how the different
indicators of tax avoidance relate to each
other and which of them really get at the
32
core of the matter instead of being rather
accidentally connected to avoidance activities. Therefore, one main focus of the
project is to provide some clarifications
on this aspect by making a functional
analysis of the various indicators. On the other hand, jurisdictions differ
widely in what kind of legal instruments
they use to tackle tax avoidance, in the
legal consequences attached to these
instruments and in their procedural
framework. Legal comparison makes it
possible to contrast different approaches
and to explain them by reference to the
particular constitutional and historical background of the fight against tax
avoidance in various jurisdictions. Due
to these particularities, it is impossible
to identify the best legal solution to the
problem. However, the comparative
analysis enlarges the toolbox of potential procedural and substantive legal elements of anti-avoidance measures and
thereby helps improving national tax
avoidance regimes.
In May 2014, the German Federal Council asked the government to install disclosure duties for tax avoidance schemes
in German tax law and to engage in an
initiative towards a uniform European
disclosure regime. This led the German
Federal Ministry of Finance to ask for advice on the feasibility of such a statutory
disclosure duty. An article co-authored
by a former and a present member of
the Institute (Beuchert, Osterloh-Konrad)
explores the legal framework of such a
regime in Germany and discusses in
depth the pros and cons. The article
comes to the conclusion that there are a
number of good reasons for introducing
a disclosure regime; however, the legislator has to be very careful not to burden taxpayers, their advisors or the tax
administration with unnecessary paperwork or superfluous information, which,
inter alia, might be an argument for limiting disclosure duties to marketed avoidance schemes. Furthermore, in order to
ensure the fairness of the tax system,
the legislator might be well advised to
combine the introduction of disclosure
duties as a measure to improve transparency vis-à-vis tax authorities with measures fostering transparency vis-à-vis the
taxpayer. In particular, the current policy
of not issuing administrative rulings on
presumably tax-driven arrangements
should be reconsidered.
d) Retroactive Application of Tax Law
One of the fundamental issues in tax law
is the extent to which legislators may
retroactively impose tax liabilities given
the taxpayer’s reliance on previous tax
law. The Department has done work regarding the constitutional limits retroactive legislation for several years. In late
2013, the German Constitutional Court
(Bundesverfassungsgericht) delivered a
widely debated judgment on “retroactive
clarifications” which fully endorsed earlier publications from the Institute (see
Schön, Festschrift Joachim Lang, 2010, p.
221) and strengthened both the separation of powers between the judicature
and the legislature and the protection of
the taxpayer under the rule of law.
Tobias Beuchert
Anzeigepflicht bei
Steuergestaltungen
Dr. Otto Schmidt
401 p.
Retroactive legislation is by no means
only a German topic. One research fellow has written a comparative article
on retroactive legislation according to
the jurisprudence of the German Federal Constitutional Court (Bundesverfassungsgericht) and the European Court of
Human Rights (Meindl-Ringler). The author examines two cases from France and
Great Britain that she compares to the
German Federal Constitutional Court’s
point of view on retroactive legislation.
In doing so, she questions the German
court’s distinction between genuine and
de facto retroactivity.
e) Enforcement and Restitution of Tax
Payments
A book entitled “Restitution of Overpaid
Tax” was co-edited by a member of the
Institute (Häcker). It is the product of
a conference held at the University of
Oxford in 2010, exploring the evolution
of claims for the recovery of overpaid
tax since the seminal House of Lords
decision in Woolwich Equitable Building
Society v Inland Revenue Commissioners
33
(1992). This area of law has undergone a
rapid development in the wake of decisions by the European Court of Justice
holding various provisions of UK tax law
to contravene basic European principles.
In particular, the finding in Metallgesellschaft/Hoechst v Inland Revenue Com-
Steven Elliott,
Birke Häcker, and
Charles Mitchell
(eds.)
Restitution of
Overpaid Tax
Hart Publishing
366 p.
missioners (2001) that the UK regime
governing intra-group dividends and
advance corporation tax infringed companies’ freedom of establishment led to
a whole spate of litigation. The first part
of the book explores the ramifications of
this national case law, while the second
approaches the topic from the European
angle. The third and last part adds a comparative dimension by considering how
other jurisdictions deal with the problem
of overpaid tax. Within this last part, one
chapter compares the English preference
for regarding the recovery of payments
made to the state (in the widest sense of
the word) as falling within the ordinary
law of unjust enrichment with the German concept of special ‘public law restitutionary claims’ (Häcker).
34
In order to avoid the liquidation of insolvent companies and further enhance
their restructuring, many countries have
abolished explicit statutory tax priorities and no longer rank tax claims before
unsecured claims by private creditors.
There are, however, other means of
granting a preferential treatment to the
government’s revenue claims: Inter alia,
tax priorities may arise from director’s
responsibility rules, tax lien provisions or
from treating tax claims as debts of the
insolvency assets. In particular regarding
indirect taxes, there remains indeed a
strong case for keeping some sort of tax
priority. The aim of one ongoing research
project is to analyse internationally established regulatory tools providing tax
priorities with special focus on their ability to conciliate the conflicting interests
of the private creditors, the debtor and
the government (Fries).
2. German and Comparative
Business Taxation
a) Corporate Income Tax
The legitimacy of corporate income tax
is constantly under review. Its role within
the framework of income tax in general
was the subject of a lecture held by Wolfgang Schön on invitation by the German
Tax Law Assocation (Deutsche Steuerjuristische Gesellschaft). He subscribed to the
traditional view that corporate income
tax fulfils the task of a “back-stop” or
“prepayment” for the individual income
tax. Its mere existence leads to several
policy choices – which entities should
be subject to transparent/intransparent
taxation, how to distinguish debt from
equity, what to do with capital gains and
what treatment shall be awarded to retained and distributed profits. Moreover,
matters of loss compensation between
the corporation and its shareholders
or specific trade taxes have to be taken
into account. In the end, the lecture developed a coherent picture of business
taxation which relies on a limited degree
of “electivity” for entity status and shies
away from one-size-fits-all solutions.
A dissertation published during the
reporting period conducted a comparative analysis regarding the concept of
constructive dividend distributions in
Germany, Austria, Switzerland, and the
United States (Gerten). The common
core of the concept in all tax jurisdictions
covered is that a constructive dividend
consists of (1) any transfer of an economic benefit from (2) a corporation to a
shareholder in his capacity as such which
is (3) not related to a formal dividend distribution. Central is the second finding,
that a distribution was made specifically
with regard to the corporation-shareholder relationship (Causa Societatis).
The standard for determining this causal
nexus is the so-called arm’s-length principle. The pivotal question is whether the
company would have granted the same
economic benefit to a third party had the
decision been made by a prudent business manager.
One doctoral student finalised a major
comparative study on change of control
and loss compensation (Hohmann). The
current unsatisfactory situation of German tax law with regard to sec.8c Corporate Income Tax Act is discussed at
Carsten Hohmann
length. Taking together the outcome of
a fine-grained comparative analysis, the
author puts forward proposals for tax
reform in Germany.
One guest scholar from Norway undertook a comparative study on the various
forms of participation exemption methods in Europe (Lindeberg). During her
stay at the Institute, she focused particularly on the German national tax system
and drew a comparison with the Norwegian participation exemption method.
b) Partnership Taxation
It has already been mentioned that the
treatment of partnerships in civil law, accounting law and taxation law is one of
the newly established mainstays of the
Department’s research. The work done
in this area was described under II.2.
c) Private Investment Income
One award-winning doctoral thesis,
completed during the reporting period
and financed by an external scholarship,
examines the recently amended legal
framework for taxing capital income of
35
3. Value Added Tax
a) Research Cooperation in the Scope
of VAT
Philipp Aigner’s doctoral thesis was
awarded the “Academic Prize” of the
Munich Chamber of Tax Consultants
(left to right): Hartmut Schwab, Monika Jachmann, Philipp Aigner, and Günther Helmhagen, November 2013.
individuals in Germany (Aigner). The
thesis particularly focuses on tax implications of the total loss in value of financial
assets held by individuals. Until 2008,
only the individuals’ regular income triggered income tax. According to the new
tax provisions, both the recurring income
and the gain or loss from selling the financial instrument are subject to income
tax. However, the amendments to the
German Income Tax Act do not address
the issue of a total loss of value of the
financial asset which is not realised by
a transaction. Against this background,
the work concludes with a proposal for a
more coherent system for taxing capital
income in Germany.
36
Research institutions often cooperate in
order to use their respective research
infrastructure in the most efficient way.
Such agreements are generally structured in a way in which one research
Institute employs technical facilities of
another research Institute for its own research and vice versa, thus leading to an
exchange of goods and services. As far as
VAT law is concerned, it is questionable
whether a mutual agreement on providing research infrastructure to each other
is taxable. This is not only a matter of academic interest but also a burning issue
for major research institutions in Europe
like the Max Planck Society itself.
Generally speaking, research institutions
are not considered a taxable person,
since the engagement in fundamental
research is a non-economic activity. If,
however, cooperating with other research institutions were considered
economic in nature, research institutions
would qualify for being taxable persons
and these activities would be subject to
VAT. Research undertaken by a member
of the Institute (Heber) lays out a possible route for beneficial interpretation
by mirroring the European concept of
the “direct, permanent and necessary
extension”, which was developed for the
business sphere of a taxpayer, to his noneconomic sphere. Her work has found its
way into a major consultation performed
by the European Commission in this area.
b) Transfer Pricing and the VAT Tax
Base
The concept of transfer pricing is used
differently depending upon the purpose
to which it is applied. As far as international taxation is concerned, the arm’s
length standard is used for an allocation
of profits to the different business units
of a multinational enterprise leading to
an allocation of taxing rights to jurisdictions in which the enterprise engages in
its business activities. From a VAT point of
view, it is questionable whether transfer
pricing as such or any transfer pricing adjustments have an impact on the VAT tax
base. This question is examined in one
research paper which shows that transfer pricing itself and any adjustments for
transfer pricing generally have no impact
on the VAT treatment of this transaction
(Heber). Only in cases where either the
supplier or the acquirer is not entitled
to a full input VAT deduction does the
VAT system provide a minimum tax base
under which transfer pricing concerns
may play a role for both intercommunity
transactions and importations of goods.
4. European Tax Law
The impact of the European Treaties and
secondary EU law remains a stronghold
of the Department in its legal research.
The work is devoted to the three major
aspects of European tax law: the impact
of the fundamental freedoms, Euro-wide
harmonisation in the tax area and the
application of the state aid provisions on
tax benefits.
Marion Hombach
Sperrklauseln im
Europäischen
Steuerrecht
Nomos
419 p.
a) Fundamental Freedoms and
Taxation
aa) General Features of the Internal
Market
The question of how to reconcile the
requirements of the Internal Market and
the tax sovereignty of the Member States
of the European Union constitutes the
eternal challenge of European tax law.
While the Court has delivered straightforward answers to the detriment of
national legislation until 2005, the recent
decade has seen the emergence of a
more balanced view in the Court’s jurisprudence which has been criticised due
to its vagueness and its lack of predictability. This has given rise to research at
the Department which tests the wealth
of judgments delivered by the Court over
the last 30 years in the area of direct
taxation against the fundamental benchmarks of the open market economy created by the European Treaties (Schön). It
turns out that cross-border “neutrality”
of taxation remains the most prominent
feature of the Internal Market. The Court
37
specificlimitationstodeductions,allowancesandsimilartaxbenefits(including
taxcredits).
Wolfgang Schön giving the Klaus-VogelLecture at the WU Vienna on “Neutrality and Territoriality – Competing or
Converging Concepts in European Tax
Law?”, October 2014.
is right when it states that “neutrality”
hastobeassessedona“unilateral”basis,
takingintoaccountonlythelegalorder
of one Member State, leaving aside instancesofdoubletaxationordisparities.
But the Court gets it wrong whenever
the judges try to apply an “overall perspective” which combines tax effects in
thehomecountryandinthehostcountryinordertoconfirmthecompatibility
of one Member State’s legislation with
the fundamental freedoms. In recent
years, the Court has stressed the concept
of“territoriality”inordertoallowfora
segmentation of taxing rights between
countriesandtheensuingobstaclesarisingfromtheterritorialcharacterofatax
claim. This goes too far as it renounces
the concept of the Internal Market as
a Euro-wide playing field for economic
actors. The territorial limitation of tax
jurisdiction does not per se strengthen
tax legislation versus the requirements
of the Internal Market; it only justifies
38
Department of Business and tax Law
A major step beyond the Internal Market is provided by the free movement
ofcapitalwhichapplies–duetoArt.63
par.1 TFEU – also with respect to third
countries and their nationals. This has
ledtoawide-reachingdebateastothe
dividing line between the freedom of
establishment (applicable only within
theterritoryoftheEU)andthefreedom
ofcapital.Inarecentpublication,itwas
shownthatthisdividinglineshouldnot
followabstractconceptsastothe“content” and “scope” of establishment visà-viscapitalmovementsandtheassessment of those facts under the relevant
domesticlegislation.Rather,oneshould
focussolelyonthepurposeofthetested
legislation:ifitismeanttoregulatecertainactivities,freedomofestablishment
shouldprevail;ifitaddressesthetransferandownershipofassetsinageneral
fashion, the free movement of capital
shouldbeexamined(Schön).
bb) fundamental freedoms and Business taxation
The influence of the fundamental freedomsonbusinesstaxationwasexamined
by several researchers at the Department.Amajortopicinthisregardisthe
“Taxation of Multinationals in Europe”
wherethemoderntoolsofgrouptaxation
conflict with the requirement of equal
treatment across the borders between
theEuropeanUnion’sMemberStates.A
general analysis of this topic was deliv-
ered at a workshop on international tax
reform organised by Harvard Law School
in Woodstock/Vermont (2012) and later
transformed into a contribution to a collected volume (Schön). Two additional publications elaborate on
details of cross-border business taxation:
an article on the compatibility of transfer
pricing adjustments (Schön) and another
article on the compatibility of CFC-Legislation with the Internal Market (Schön).
One of the main findings of these three
publications lies in the fact that the European Court of Justice has moved itself
into a corner which leaves not much
leeway for Member States to establish a
coherent system of international group
taxation in the Internal Market. The reason is that the Court has accepted hardly
any justification for special treatment of
cross-border dealings within corporate
groups. Apart from the requirements of
fiscal supervision, the CJEU is only willing to allow less advantageous treatment
under tax law if there is outright “abuse”
on the side of the taxpayer, meaning
“purely artificial arrangements” devoid
of any economic substance.
Corporate exit taxation is an obvious
impediment to the internal market, as it
discriminates against cross-border business activities. The CJEU’s decision in
the National Grid Indus case (C-371/10)
in November 2011 marked the starting
point for a string of decisions, culminating in DMC (164/12) in 2014, in which
the court specified the requirements
for corporate exit taxation that follow
from the fundamental freedoms. It has
thus become evident that corporate exit
taxation cannot be addressed in a satisfactory way through CJEU jurisprudence.
An article published in the British Tax Review in 2014 shows that, in order to bring
corporate exit taxation more in line with
the logic of the internal market, it has
to be co-ordinated (Röder). The article
describes how a co-ordinated corporate
exit taxation regime should be designed
and how it could be implemented within
Isabelle Richelle
Wolfgang Schön
Edoardo Traversa (eds.)
Allocating Taxing
Powers within the
European Union
Springer
XI + 220 p.
the EU, in the context of a common corporate tax base or through a targeted
harmonisation measure, as well as outside the EU in bilateral Double Taxation
Conventions.
The European rules on exit taxation are
also the object of research undertaken by
a guest researcher (Humboldt Scholar) of
the Institute (Miyamoto). This work has
a special focus on judgments of the German Federal Fiscal Court (Bundesfinanzhof) and the CJEU on exit taxation. The
German system will also be compared
with the Japanese exit tax system.
39
cc) Free Movements of Persons between the EU and Switzerland
According to CJEU case law, the fundamental freedoms have a strong impact
on direct taxation since member states
are prohibited from designing national
tax law in a way that infringes one of
these freedoms. As a non-member-state,
Switzerland is not bound by this case law.
However, the “Agreement of Free Movement of Persons” (AFM) signed between
the EU, its member states, and Switzerland, guarantees for all parties are laid
down that show characteristics which
are quite similar to those of the fundamental freedoms. An ongoing doctoral
thesis analyses the question of whether
the case law of the CJEU is applicable to
the AFM since it shows similarities to the
fundamental freedoms (Sunde).
dd) Administrative Requirements and
Justification
In cross-border cases, it can be difficult
for tax authorities and taxpayers alike to
investigate or provide evidence for the
relevant facts influencing a tax assessment. Difficulties are caused, on the one
hand, by limited cross-border investigative powers of financial authorities, and
on the other by a plethora of hitherto
unadjusted legal rules, business practices and administrative conventions. As
a consequence, taxpayers are frequently
disadvantaged either by paying higher
taxes or by having to put extra effort into
meeting procedural obligations.
40
One ongoing doctoral thesis examines
whether and to what extent such disadvantages constitute an infringement of
European fundamental freedoms (Hennigs). It does so primarily by reference to
the case law of the CJEU which it subjects
to a critical evaluation. The emphasis
of the analysis lies on the justificatory
stage, namely how European law accommodates the interest of member states
in an effective and economically efficient
system of tax control. Another question
addressed by the project is whether
and – if so – under what circumstances
national rules relating to tax and tax procedure which are indistinctly applicable
to purely national and cross-border cases
are at all to be seen as restrictions on
fundamental freedoms calling for an appropriate justification.
b) Tax Harmonisation
aa) Enhanced Cooperation
The enhanced cooperation procedure
is a mechanism laid down in the treaties of the European Union allowing
at least nine Member States to use the
institutions of the European Union for
establishing a legal framework between
themselves in a particular field that does
not fall within the exclusive competence
of the Union. This European mechanism
of differentiated integration has hardly
been used since its implementation in
the framework of the Treaties in 1999,
and thus, not much attention has been
given analysing the legal requirements
for establishing enhanced cooperation
between member states and its legal
consequences. Despite the lack of prac-
tical pertinence in the past, this mechanism has the potential of becoming a
pioneer for achieving tax harmonisation.
Policy makers have acknowledged, more
than ever before, that especially in the
field of taxation a more collaborative approach has to be pursued.
A new post-doctoral project dealing with
the enhanced cooperation procedure in
tax law just started in 2014 (Heber). This
work will not be limited to a legal analysis of this procedure since policy issues
will also be subject to this research work.
The research work will strongly be driven
by the concept of the European internal
market, and thus, the work will have
a special focus on the policy question
of whether tax harmonisation among
some but not all member states under
the enhanced cooperation procedure
will strengthen or harm the establishment and functioning of the European
internal market. On the other hand, the
legal effects of an enhanced cooperation
between some but not all member states
with respect to the European market
concept have to be analysed.
bb) Common Consolidated Corporate
Tax Base
One doctoral thesis, completed in 2013,
analyses the computation of profits according to the proposed Directive for a
Common Consolidated Corporate Tax
Base (CCCTB) (Eggert). The harmonisation of the computation of the corporate
tax base according to the proposal for a
CCCTB is a comprehensive harmonisation
project that concerns all areas of tax ac-
Andreas Eggert was awarded the prestigious Mitchell B. Carroll Prize by the
International Fiscal Association (IFA), in
Mumbai, India, October 2014.
counting law. There are many open questions regarding the general principles for
the determination of the taxable profit
as well as the provisions in detail. In this
thesis, a comparison is drawn between
the computation of corporate profits
for tax purposes pursuant to the CCCTB
rules, and the computation methods
according to the German Commercial
Code (HGB), the German Income Tax Act
(EStG), and the International Financial
Reporting Standards (IFRS). This work
discusses the differences and similarities
between these different sets of rules to
ascertain whether the proposed profit
computation method is a feasible tool for
tax harmonisation in the EU. This thesis
was awarded the Mitchell B. Carroll Prize
2014 by the International Fiscal Association (IFA), and has been published in
2015.
Particular aspects of the computation of
profits under the CCCTB also lie at the
heart of another piece of research work
(Eggert). Under the CCCTB concept, one
41
of the important issues is the treatment
of partnership interest in tax transparent entities. Especially in Germany, this
treatment will be of great importance.
This article examines the tax profit calculation of a partnership where at least
one of the partners is a corporation that
is taxed under the CCCTB rules.
One doctoral thesis closely linked to issues of European direct tax harmonisation entitled “IP Migration – Taxation of
IP Holding Companies” was nearly completed during the reporting period (von
Einem). In 2014, the author published an
article which laid out a proposal to amend
the Interest-Royalty Directive to take account of some of the recent “abuses” of
IP holding regimes under European law.
DERIVATIVES
& FINANCIAL
INSTRUMENTS
Volume 16 - Number 3 - 2014
Articles
International
• Over-the-Counter Derivative Markets in the Light
of EMIR Clearing Obligations and the Financial
Transaction Tax
Netherlands
• The Implementation of the AIFMD in Dutch Tax
Law
International
• Anti-Abuse under the Financial Transaction Tax
Proposal
International
• Retailers Directly Accepting Bitcoins: Tricky Tax
Issues?
Comparative Survey – Crowdfunding
Australia
Recent Developments
International; Spain
For information about IBFD publications and activities
please visit our website at www.ibfd.org
INTERNATIONAL TAXATION, REGULATION AND ACCOUNTING
With their article “Over-the-Counter
Derivative Markets in the Light of EMIR
Clearing Obligations and the Financial
Transaction Tax”, Christian Sternberg
and Caroline Heber came first at the
“DFI Writing Competition 2014”.
42
cc) Financial Transaction Tax
As early as 2012, one author exposed
the main contradictions and ideological
flaws of the new attempt to tax transactions in financial instruments at a European level (Schön). It was demonstrated
to what extent the introduction of a financial transaction tax (FTT) boils down
to “symbolic politics” which does not further substantially the aims of a European
Capital Market.
In several contributions, two members
of the Institute analyse the interplay
between the second European proposal
for a FTT and financial market structures
and regulation (Heber, Sternberg). The
authors conclude that in both organised
markets and over-the-counter trading
the financial transaction tax does not
sufficiently account for market structures and regulative requirements;
therefore, they suggest revising the proposal for a financial transaction tax. In
organised markets, with central counterparties, clearing members that are the
only institutions allowed to enter into
transactions with central counterparties and central securities depositories,
trading structures have evolved that
are desirable to reduce systemic risks
in financial markets. That is why for certain standardised financial instruments
not yet commonly traded on organised
markets, financial market regulation requires these financial instruments to be
traded on organised markets. Moreover,
certain derivative contracts that are not
suitable for trading on organised markets
but sufficiently standardised have to be
cleared through a central counterparty.
Although these market structures and
obligations are very important for sustaining financial market stability, clearing
over-the-counter trades through central
counterparties as well as transactions
with clearing members are still subject
to the proposed financial transaction tax.
This creates an incentive to alter trading
behaviour and market structures, which
would most likely increase systemic risks
in financial markets. Moreover, the scope
for selling financial instruments short has
been limited by a regulation. Its aim is to
assure the settlement of short-selling,
thereby increasing market stability. If
the seller cannot settle the trade in due
time, as a mechanism of last resort, it
provides for a buy-in procedure by a central counterparty that buys the financial
instruments sold short on the market
and delivers these to the original buyer.
However, since central counterparties
are exempt, this may create an incentive
not to settle a short sale in due time. This
will increase systemic risks in financial
markets contrary to the aims of the regulation and financial transaction tax.
The taxation of financial transaction also
lies at the heart of a piece of research
undertaken by a guest researcher of
the Institute (Said Formosa). This work
compares the existing taxes on financial
transactions with the proposed European FTT. Tax policy issues from a legal and
non-legal perspective are the main focus
of this research.
c) State Aid Law and Tax Law
As in the previous reporting period, the
interaction between the state aid provi-
Chiara Balbinot
sions under the Treaty on the Functioning of the European Union and domestic
tax legislation played a dominant role in
the work of the Institute. In 2012, an update of the general chapter on “State Aid
Law in the Area of Taxation” in a leading
handbook on state aids was published
(Schön). Moreover, current topics like
the impact of the prohibition on state aid
on “unfair” tax competition, in particular beneficial “rulings” issued by some
Member States in favor of multinational
business, were discussed for a general
audience.
One doctoral thesis, completed in 2014,
deals with the interplay between state
aid law and tax neutrality (Balbinot). The
aim of this research project is twofold:
First, it intends to define the notion of
state aid in the area of direct taxation
with regard to the CJEU’s case law, the
European Commission’s approach, and
the current academic literature. Second,
it answers – based on the notion of State
Aid found – the question of whether
the lacking tax neutrality regarding different legal forms, i.e. corporations and
partnerships, constitutes state aid in the
meaning of Article 107 of the TFEU.
43
State aid and tax law also lies at heart
of another ongoing doctoral thesis (Jozipović). This doctoral thesis, however,
aims at analysing the impact of EU state
aid law on rules of international tax law.
State aid law is in general applicable to
all areas of law. However, international
tax law is often considered as a technical
norm system that serves the main purpose of supporting the material law. As
such, the Commission has considered it
as being in line with state aid law as long
as it serves its technical purpose. Despite
this, recent developments (e.g. the BEPS
project of the OECD and the Commission’s procedures against tax planning
schemes of multinationals) show the
need for analysing the structure of international tax law from a state aid perspective.
Another piece of research work in this
field of law discusses the Croatian accession to the EU from a combined tax and
state aid point of view (Jozipović). This
Marta Oliveros Castelon and Christian
Sternberg both work on international
taxation. Pictured at the Institute’s
Staff Retreat in September 2013.
44
paper examines the accession contract
between Croatia and the EU with respect
to existing state aid law, and contracts of
prior accessions. The paper criticises in
particular the one sided risk distribution
in which Croatia as an applicant and now
as a new member state is responsible for
potential hidden state aids of which neither the state nor the Commission were
aware of.
5. International Taxation
The taxation of cross-border activities
and investment is one of the mainstays
of the Department’s work in the area of
taxation.
a) International Allocation of Taxing
Rights
As in previous years, the international
allocation of taxing rights has been the
subject of intense research at the Institute. One of the Department’s major
fields of work in the reporting period is
the rearrangement of tax jurisdictions in
a globalised economy. The impact of the
BEPS project on this work has already
been described above (II.3.). The Institute closely monitors the tectonic moves
of the international landscape of taxation
and tries to address both fundamental long-term topics and current issues
which arise from the political debate.
In a globalised economy, a person’s behaviour is not limited to the territory of
a single state. Instead, persons are active
within many states and their actions have
cross-border reach. States try to follow
suit and enact laws with extraterritorial reach, sometimes in a harmonised
manner like in the European Union. If
states try to realise their policy goals in a
globalised world by enacting law with extraterritorial reach, persons will be faced
with multiple and sometimes conflicting
rules. From a states’ perspective, rules
with extraterritorial reach enacted by
another state will impede with its very
own policy interests. Therefore, one doctoral thesis aims at analysing whether
public international law, European law
and German constitutional law set out
limits for states’ extraterritorial jurisdiction (Sternberg).
b) International Taxation of Services
The taxation of income from the international services provisions is presently
one of the most controversial issues
in the tax arena. This is because the
advancement of technology more and
more allows service providers to have
a great penetration in a country’s market without having permanent physical
premises there. Especially, the possibility
of remote services provision has increasingly lead the countries that are net
services importers – mostly developing
countries – to challenge the adequacy
and the legitimacy of the division of
tax competence according to the OECD
Model Double Tax Convention. This is because this model conditions the service
importer’s country right to tax income
upon the existence of a permanent establishment in that country, which, as
a rule, requires the existence of a fixed
place of business of the services provider
in the host country.
In this context, one research fellow
analyses the treaty practice of both net
capital importers such as Brazil and India, and net services exporters, such as
Germany and the United States (Oliveros
Castelon). Moreover, she tries to answer
the question as to whether legal and
economic principles may give a normative orientation as to how the right to
tax income from international provision
of enterprise services should be divided
between the states.
c) Limitation on Deductibility
of Interest
Two doctoral theses completed during
the reporting period examine the interest barrier rules in Germany introduced
in 2008 as a means of preventing profit
shifting and of increasing the equity ratio (Jehlin, Marquardt). Multinationals
often engage in internal lending with the
intent to debt finance German companies within the group. As a result, the tax
base is eroded in Germany. The principal
aim of the German interest barrier is to
prohibit exactly such behaviour.
One doctoral thesis (Jehlin) focuses on an
analysis of the German provisions in the
light of constitutional law and in particular Art. 3 (equal treatment) and Art. 14
(protection of property) of the German
Constitution. The constitutional analysis
is supported by findings of recent empirical economic surveys studying the effect
of the interest barrier. The author reaches
45
Alexander Jehlin
Die Zinsschranke als
Instrument zur
Missbrauchsvermeidung und Steigerung
der Eigenkapitalausstattung
Duncker & Humblot,
267 p.
the conclusion that the German interest
barrier constitutes a breach of constitutional rights which cannot be justified.
The other doctoral thesis published in
2012 (but completed during the previous
reporting period) covers the limitation
on deductibility of interest from the per-
Christian Marquart’s doctoral work was
awarded with several prizes: the Promotionspreis of the Esche-Schümann-Commichau-Stiftung, the Gerhard-Thoma
Prize of Honour from the Fachinstitut
der Steuerberater e.V., and the Academic Prize of the Munich Chamber of Tax
Consultants. Here Marquart (middle)
is pictured with Hartmut Schwab (left)
and Günter Helmhagen (right) from the
StbK München, October 2014.
46
spective of comparative law (Marquart)
and comes forward with policy recommendations. It speaks out in favour of
an interest allocation rule having regard
to asset allocation within the corporate
group in the first place. This doctoral thesis was awarded three major academic
prizes for doctoral work (see bottom left)
and can therefore be regarded as one of
the Department’s most visible outputs in
the reporting period.
d) Taxation of Permanent
Establishments
The taxation of permanent establishments is driven by two major factors: the
scope of the concept of a permanent establishment under Art.5 OECD Model and
the attribution of profits to a permanent
establishment under Art.7 OECD Model.
The first issue is addressed in a publication which aims at a more sophisticated
understanding of the concept in general
(Schön). On the one hand, the notion of
a permanent establishment serves the
purpose of determining the threshold for
source taxation of cross-border business
income. On the other hand, the notion
of a permanent establishment is employed to hypothesize a fictitious entity
which might enter into “dealings” with
the head office of the company, is able
to employ salaried persons and might
even rely on double taxation convention
benefits itself. From the author’s point of
view, it seems advisable to disentangle
these concepts and to separate the right
threshold for source taxation from several other functions under national and
international tax law.
One doctoral thesis (Holm) deals with
the attribution of profits to permanent
establishments under German tax law.
A major part of this project is devoted
to the interpretation of section 1 of the
German Foreign Transaction Tax Act
(Außensteuergesetz). This part is manly
inspired by the legislator’s intention to introduce the Authorised OECD Approach
(AOA) into national law. The AOA is an
international concept aiming at dividing
taxing rights between two countries in
which one enterprise operates. One of
these states is the state of residence and
the other one is the state in which the
enterprise operates through its permanent establishment. The AOA requires
treating a permanent establishment as a
separate and independent entity for the
purpose of allocating profits. The second
major part of this thesis is an examination of the interplay between section 1
German Foreign Tax Transaction Act and
other provisions of domestic tax law
addressing the relationship between a
permanent establishment and the headquarters in a multinational enterprise.
e) Hybrid Entities and Double
Non-Taxation
A new research project on international
double non-taxation derived from the
use of hybrid entities has started in 2014
(Parada). The first part of this thesis
includes an analysis of the concept of
double non-taxation in the international
arena in order to understand that double non-taxation need not always be
considered a problem. In contrast, in
many cases it can be accepted or even
Christian Marquart
Zinsabzug und
steuerliche
Gewinnallokation
Nomos
IX + 148 p.
intended by domestic laws and tax treaties, and it can be used as an important
and positive tool for tax policy. The second and third part of this thesis analyse
the concept of hybrid entities and the
conflicts of allocation derived from the
disparity between domestic laws in classifying foreign entities for tax purposes.
For this purpose, the author provides a
comparative analysis of the main classification systems used around the world
and analyses the practical possibilities of
coordinating them on an international
level in order to avoid abusive situations.
Another piece of research in this area
analyses a decision of the German Federal Fiscal Court on whether allowance
for corporate equity (ACE) should be
categorised as dividend or as interest
under the former double tax convention
between Brazil and Germany (Oliveros
Castelon). Brazil is one of the few countries in the world that has included an
ACE regime in its legislation, called “juros
sobre o capital próprio” (literally: interest
on equity). The ACE regime, therefore,
is hybrid for tax purposes. Against this
background, the German Federal Fiscal
47
Court has reached the conclusion that
ACE should be qualified as dividends for
the purposes of the German-Brazilian
DTC. In the article the author presents
the decision of the Court and also the
reasons why she thinks that this decision
deserves criticism. She argues that the
Court should have attached more importance to the DTC provision stating that
the term interest included “other income
assimilated to income from money lent
by the taxation law of the Contracting
State in which the income arises”.
f) The Concept of Beneficial
Ownership
Beneficial ownership is a concept found
in the OECD Model (and tax treaties in
general) in the articles on dividends, interest and royalties. In the OECD Model,
the term was originally intended to exclude agents and nominees from claiming treaty benefits; yet the exact meaning of the term has remained unclear.
There are a number of approaches to
beneficial ownership. For instance, the
term is often used in the sense of a narrow anti-avoidance provision targeted
at certain types of conduit companies,
whereas others would rather like to see
beneficial ownership interpreted as an
attribution of income rule. One ongoing
research project discusses not only the
OECD situation, it also compares the use
of beneficial ownership in a number of
countries, amongst others, Germany, the
U.K., and Australia, taking into account
the current and historical understanding
of the term (Meindl-Ringler). Therefore,
archival material on U.K., and Austral-
48
ian tax treaties from the 1960s is taken
into account. The aim of this thesis is
to determine how beneficial ownership
should ideally be interpreted considering, inter alia, historical material, the
purposes of tax treaties and the growing
need to target conduit structures.
g) Mutual Agreement Procedure
A tax treaty signed between two states
generally seeks to prevent double taxation by providing for a uniform allocation
of taxing rights with respect to different
classes of income between the state of
residence and the source state. Even
though treaties are in force, double
taxation may still arise. Such double
taxation may result from incorrect application of the treaty by one contracting
state or from different views between
the contracting states. To resolve issues on remaining double taxation, tax
treaties typically provide for a Mutual
Agreement Procedure (MAP). A visiting
professor (Ault) analysed this procedure
in more detail. The author described in
some detail the various situations in
which the MAP can be used to ensure
the proper functioning of the treaty. Two
sources are of particular importance for
this research work: the UN Guide to the
Mutual Agreement Procedure under Tax
Treaties and the OECD Manual on Effective Mutual Agreement Procedure.
h) Climate Policy
During the last decade, a growing social sensitivity towards ecological issues
drove an ever-increasing request to
governments about introducing suitable
economical instruments in order to prevent noxious effects on the environment
due to polluting substances. In such a
context, one of the most effective economical instruments, both in terms of
efficacy in safeguarding the environment
from pollution and in terms of economic
efficiency, has turned out to be the introduction of environmental taxes.
Two guest researchers of the Institute
(Pitrone and Pirlot) have independently
analysed the concept of environmental
tax reforms (the need and rationale) and
of environmental taxes, on the evolution
of environmental taxation in the international and in the EU perspective and
the German environmental tax reform.
Another contribution analyses the Greek
Tax System for exploration and production of hydrocarbons in Greece according
to the Greek Statute number 2289/95
(Andrianesis).
i) Tax and Investment Treaties
Tax and investment treaties are considered as separate regimes and are fragmented as a result of the estimated 3.000
bilateral treaties negotiated throughout
the 20th century. Tax treaties primarily
focus on how to split the pie of revenues.
Investment treaty provisions go beyond
the allocation of tax jurisdiction and emphasise the promotion of foreign direct
investment by granting special standards
of treatment to investments. A guest
researcher of the Institute (Frahm) explored the tax-investment nexus. The
Carina Frahm held a guest scholarship
at the Department in autumn 2013. She
worked on tax and investment treaties.
work attempts to substantiate how the
symmetries and asymmetries of each
regime work together and how to offer
coordination improvements.
6. Foreign Tax Law
a) Exchange of Information
Some research has been undertaken
in the field of exchange of information
between countries with a special focus
on the Foreign Account Tax Compliance
Act (FATCA), a new U.S. tax policy that
requires foreign financial institutions
around the world to provide financial information to the IRS regarding their U.S.
clients. The first of a series of papers analysed the proposal for a new regulation
of the European Parliament and of the
European Council with the objective of
establishing new parameters to improve
the operation of the taxations systems in
the European Union as well as to support
the fight against tax fraud, tax evasion,
and aggressive tax planning in the region
(Parada). The second paper in this series
49
b) Provisions on Controlled
Foreign Companies
Volume 74/2014 of Tax Notes International, including the article “Lessons
Learned From the Swiss Julius Baer
Case“ by Leopoldo Parada.
analyses the effectiveness of FATCA in
light of a recent Swiss Court decision that
blocked the disclosure of account information made to the U.S. through a group
request (Parada).
Based on this work, the final research
piece provides a critic analysis of the
Intergovernmental Agreements (IGAs)
used to facilitate the international coordination in the exchange of information
as well as to serve as an opportunity for
many countries in Europe to increase
their own information network with the
United States (Parada). The paper concludes describing and analysing three issues that must still be clarified in the process of FATCA implementation in Europe:
1) the use of “quoted Eurobonds” in the
U.K. and the potential FATCA arbitrage
derived from their use; 2) the group requests allowed under the Swiss IGA, and
3) the “coordination timing” provision of
the IGA Model 1A in light of the reciprocity in the exchange of information. In
2015, this paper has been accepted for
publication by the World Tax Journal.
50
One article dealing with the jurisprudential developments of the Brazilian
CFC rules was co-authored by Gerd Willi
Rothmann (University of São Paulo) and
a research fellow of the Institute (Oliveros Castelon). These rules used to be
strongly criticised in the tax literature
due to their far-reaching scope. In fact,
the CFC regime foresaw the taxation in
Brazil of profits of foreign controlled and
affiliated companies and irrespective
of whether the income earned abroad
could be classified as passive. Therefore,
the CFC-regime was considered as incompatible with the idea of proportionality,
given that the measures implemented to
combat specific tax avoidance structures
encompassed a great spectrum of cases
where no tax avoidance purpose could be
identified. In presenting the main settled
and pending cases concerning the Brazilian CFC rules, the article gave special
attention to a constitutional claim (“ação
direta de inconstitucionalidade” – ADI –
n° 2588) that was pending at that time.
In the meantime, this case has been settled, and the CFC regime was considered
as partially incompatible with the Constitution. As a reaction to this decision, the
CFC legislation was partially revised.
Another piece of research on foreign CFC
rules was undertaken by one member
of the Institute (Jozipović). The paper
analyses the specifics of the Croatian
legal system regarding reinvestments of
profits in comparison with standard CFClegislation.
VI Business Law
1. Financial Accounting
a) Accounting for Intra-Group
Transactions
In recent years, several developments
at the European level have led to increased discussion of accounting rules
for intra-group transactions or relatedparty transactions. One of these factors
was the CJEU’s decision in the GIMLE
case which addressed the recognition
and valuation of the transfer of shares
between a shareholder and a company
if this transfer is deliberately executed
at under-value. While the CJEU had no
issue with accepting such an erroneous
transaction, the outcome runs into the
face of several accounting principles, in
particular the necessity to distinguish
between capital contributions (generated by the shareholder) and business
profits (generated by the corporation). In
a clear-cut case note on the GIMLE judgment, the inherent flaws of the Court’s
reasoning were exposed both from a
comparative law perspective and from
an EU law perspective. There is strong
evidence that the CJEU has to go deeper
into the subject matter (Schön).
Moreover, a doctoral thesis that is close
to completion is devoted to the “disclosure of related party transactions in the
financial statements of a corporation”
(Andrianesis). This work focuses on the
connection of intra-group transactions
that have not been concluded under
normal market conditions with the
preparation of the financial statements
according to the true and fair view of the
financial performance and position of
the company under German law (HGB).
In particular, it proposes a way of estimating the deviation from the “normal
market conditions” and how those transactions should be properly disclosed and
accounted for in the financial statements
of the entity. Intra-group transactions
that are concluded in a non-market environment can easily deviate from market
conditions. This deviation also leads to
distortions in the financial statements
of the company, which are used not only
for informational purposes, but also for
the distribution of the profits. Financial
statements can (and should) describe
a more “objective” and “non entityspecific” view of asset transfers between
related parties, as long as it is clear to
the users of the financial statements that
those deviations could be economically
explained. It is then a problem of tax and
company law to track down and filter out
transactions that lack economic justification.
b) Accounting Limits to
Profit Distribution
One doctoral research project analyses
problems of statutory constraints on
dividend distributions (Klinkert). German corporate and accounting law prohibits distribution of certain assets that
are considered closely connected to the
corporation. The prohibition serves as a
creditor-protection mechanism. This ongoing research project focuses specifically on the statutory constraints imposed
51
by section 268 subsection 8 of the German Commercial Code (HGB). The provision was enacted in 2008 trying to align
national accounting with international
standards (such as US-GAAP or IFRS). In
practice, this rule gave rise to a number
of problems that are analysed comparatively in this research work. The author
particularly focuses on the accounting
law in California that was similar to the
German provision. In 2011, the Californian legislator addressed problems comparable to those existing in Germany.
The doctoral thesis aims at proposing
solutions to issues raised by the German
accounting rules.
c) Auditor Rules in Europe
In November 2011, the European Commission published legislative drafts
proposing radical reforms for statutory
audits in Europe, fuelling heated political and academic debates. One senior
research fellow of the Institute (Hellgardt) participated in a joint paper in
which cornerstones for a new regulatory
framework of auditing were presented.
This paper contributes to the ongoing
debate on the role of auditors and their
independence.
Carlo Pohlhausen
Unternehmensfinanzierung am
Kapitalmarkt in den
arabischen Staaten
Mohr Siebeck
XXXII + 796 p.
52
2. Capital Markets Law
a) General Aspects of Financial Market Regulation
The financial crisis revealed major problems in the regulation and management
of financial institutions across the world.
According to one senior research fellow
(Hellgardt), it is remarkable that the general discussion about reforming financial
regulation is focused on the substantive
standards to be established with new
rules while neglecting the problem of
choosing the right regulatory instruments. This article analyses the relative
strengths and weaknesses of four basic
instruments of law enforcement - administrative sanctions, civil liability, corrective taxation and criminal sanctions – and
employs a cost-benefit analysis. It turns
out that civil liability – while limited in
its scope – exhibits the best cost-benefit
ratio. Criminal law, by contrast, seems
very inefficient. Administrative law and
corrective taxation come in second best.
However, according to this paper, the return from using these instruments has to
be assessed on a case-by-case basis.
b) Capital Market Liability
One piece of research work analyses the
standards of European Union law as regards capital market liability and its consequences for German law (Hellgardt). So
far, the discussion has centred on the few
provisions demanding civil law remedies,
such as Art. 6 Prospectus Directive and
Art. 7 Transparency Directive. However,
the paper shows that the CJEU case-law
mandates far-reaching private rights of
action even in fields of law that do not
contain any explicit provision on liability.
This is especially relevant for all forms of
mandated disclosure in European capital market law. Furthermore, the paper
analyses the consequences of the draft
market abuse regulation for private remedies in Germany. As in competition law,
unification might boost private rights of
action also in capital market law. On the
occasion of the judgement on civil liability of the IKB-bank for a misleading press
statement disguising its involvement in
risky U.S. subprime mortgages, one paper analyses the decision of the German
Federal Court on capital market liability
(Hellgardt). The paper raises two conceptual issues emanating from the Supreme
Court’s case-law: There seems to be a
contradiction between the protective
scope of the provisions on capital market
liability, which aim to protect only monetary interests, and their application by
the Federal Court, which emphasises the
freedom to make investment decisions.
Also, the IKB-judgement has obscured
the relationship between liability for the
publication of misleading information
and liability for the omission to make a
required disclosure. Another article in
this area analyses the law on liability
for misleading information to investors
(especially for misleading prospectuses)
outside the organised capital markets
(Hellgardt). At the beginning, the caselaw of the Federal Court in Karlsruhe
dominated this field of law, but in recent
years the legislator passed several statutes containing provisions which diverge
substantially from prior court-rulings.
Nevertheless, the Supreme Court continues to issue judgements on the law prior
Angelika Meindl-Ringler (left), Marta
Oliveros Castelon (middle), and Julian
Schroeder (right) in September 2013.
to the enactment of the statutes, without taking even notice of the fact that
only a short time after the case on trial,
the legal framework changed dramatically. Against this background the paper
takes a functional approach to merge the
divergent sets of rules into one single
standard for capital market liability outside the stock exchanges. In particular,
two areas are examined: Which pieces
of information may constitute liability?
Who will be liable?
One doctoral thesis analyses the personal scope of the prospectus liability
under sections 21 et seq. of the German
Securities Prospectus Act (WpPG) and
20 et seq. of the German Investment
Act (VermAnlG) (Schroeder). One of this
work’s major research questions is which
persons involved in an IPO or capital increase that require a prospectus should
be held liable from an economic point of
view. The author develops his own approach; this is done by transferring the
predominant view of the German courts
and the relevant legal literature that is
expressed in the context of due diligence
to the context of the personal scope and
used it for the determination of the li-
53
able persons. The economic analysis as
well as the author’s own approach lead
to the conclusion that the issuer, the participating investment bank, the auditor
and also the managing directors should
be held liable, provided that they acted
at least with gross negligence regarding
the untrue statement or the omission in
the prospectus. Under certain circumstances, the same applies to the parent
company and/or the major shareholder. Another piece of research work discusses
the Greek legal framework of claims for
damages of the minority shareholders
of a listed company in the cases where a
person illegally did not file a mandatory
bid as it was supposed to (Andrianesis).
Abuse Directive (Hellgardt). Geltl concerned the step-down of Mr. Schrempp,
the former CEO of DaimlerChrysler,
which allegedly was reported too late to
the capital markets. The judgement rejected the view of the German Supreme
Court (BGH) that situations described as
“protracted processes” warrant a specific interpretation of the notion of inside
information. The paper highlights several
important outcomes of the case: First,
the CJEU clarified that ad hoc disclosures
according to Article 6(1) Market Abuse
Directive are a means to prevent insider
dealing, and, hence, the notion of inside
information must not be interpreted differently in the context of such disclosure
duties. Second, the paper argues that the
notion of “intermediate steps” in a larger
decision process is conceptually flawed
and not supported by the mechanisms
of information processing in capital markets. Finally, the paper stresses the importance of distinguishing between the
concepts of “precise information” and
“potential price effects” in the definition
of inside information.
d) Transfer of Securities
Common Market Law Review 50/2013,
including Alexander Hellgardt‘s article
“The Notion of Inside Information in the
Market Abuse Directive“.
c) Market Abuse
One piece of research reviews the CJEU’s
Geltl-judgement, in which the Court
ruled on the notion of inside information
according to Article 1(1) of the Market
54
The UNIDROIT Convention on Substantive Rules for Intermediated Securities
was adopted in 2009 to create a common
legal framework for the holding, transfer
and collateralisation of intermediated
securities. In modern security markets,
certificated securities are displaced by
electronic book-entries in security accounts held with financial intermediaries and transferred electronically. The
legal concepts of the contracting states
of the Convention differ considerably
from each other: some jurisdictions (e.g.
Germany) still apply traditional property
law concepts which focus on the security
certificate, the investor is treated as the
legal owner of the security and has a
direct legal relationship with the issuer
whereas the intermediary has no legal
title to the securities. In other jurisdictions (e.g. Great Britain) the legal relationship of the investor with the issuer is
disrupted in the system of intermediated
securities and displaced by rights of the
investor against his intermediary. The
Geneva Securities Convention aims at
harmonising the rules on intermediated
securities and thereby maximising legal
certainty without interfering with the
different legal concepts of the member
states (functional approach). In one doctoral thesis, the author analyses to what
extent the rules on transfer, innocent acquisition, collateralisation and priority in
the Convention increase legal certainty
on the one hand, and are compatible
with the corresponding rules in Germany
and the United Kingdom on the other
hand (Risch).
3. Partnership Law
It has been mentioned that partnership
law is one of the current mainstays of
the department’s research. The extensive work done in the context of civil
partnerships and commercial partnerships – both with regard to the aspects
of private law and accounting law – was
summarised above (II.2.).
4. Corporate Law
a) Fundamentals
In the reporting period, a major piece
of literature on fundamental aspects of
corporate law was completed and transformed into a book publication jointly
with co-authors from the Max Planck
Institute in Hamburg and several universities. This book is meant to address from
first principles the question of how to design the regulatory framework for closed
companies. While the concept and the
challenges of public companies are widely researched (in particular in the U.S.
and in the UK), closed companies – ranging from family-owned business to joint
ventures and private-equity firms – are
rarely addressed in a systematic manner.
One author (Schön) drafted the book’s
chapter on creditor protection, taking
into account the interaction between
shareholders and directors which is far
more dangerous for creditors in closed
companies than in public companies. The
work is informed by economic underpinnings of creditor protection, the enabling function of corporate law and the
incentive effects of legal safeguards with
regard to an optimal allocation of corporate assets (including an optimal choice
of corporate risk). In this vein, corporate
law has to be aligned with insolvency law
which brings about specific issues of administrative powers (shareholders, directors, outside executors) and trusteeship
(for the creditors, for the shareholders or
for whom)?
The book which has been published both
in German and in English has been selected in 2014 as one of the “legal books
55
of the year”, a rare accolade granted only
to very few publications across all fields
of law in Germany.
b) Aspects of European Corporate Law
Like in the areas of accounting and
taxation, some major publications have
been devoted to fundamental aspects
of European Company Law. In 2012,
the CJEU delivered its landmark judgment in “VALE” where it was held that
a company established in one Member
Gregor Bachmann
Horst Eidenmüller
Andreas Engert
Holger Fleischer
Wolfgang Schön (eds.)
Rechtsregeln für die
geschlossene Kapitalgesellschaft
ZGR Special Volume
De Gryuter
235 p.
State is entitled to seek transformation
into the legal form offered by another
Member State. The state of destination
is obliged to allow the foreign entity this
change of legal form along the lines of
those transformation rules which are
applicable for domestic transactions.
This judgment marks the final word in
a saga which began in 1988 with the famous “Daily Mail” judgment and which
has been monitored in writings from the
Department ever since. In an extensive
case note to “VALE” the Department’s
director laid out the general framework
56
for corporate mobility in the European
Union as established by the strand of
jurisprudence from 1988 to 2012 and
endorsed the move of the CJEU towards
to shareholder-friendly system where
regulatory competition and free movement supersede protectionist legislation
in the Member States. At the same time,
the jurisprudence of the CJEU leaves it to
the Member States to define the types of
companies available under domestic law
and therefore does not interfere fundamentally with the power to legislate in
this area (Schön).
A follow-up aspect to the freedom of
legislators in the area of company law
(outside harmonised fields like accounting, disclosure or capital maintenance)
concerns the concept of limited liability.
A recent decision of the CJEU in the Idryma Typou case gave rise to the question
whether Member States are obliged by
the European Treaties and under secondary law to introduce at least one legal
form offering limited liability to market
citizens and to what extent they are entitled to withdraw this privilege for certain
cases. It turns out that Member States
enjoy a large amount of discretion in this
area but they have to offer a menu for
economic actors to engage in cross-border business both in an unincorporated
and an incorporated fashion. To a certain degree, measures of group law and
similar regimes which lift the corporate
veil have to be justified in the light of the
Internal Market (Schön).
One piece of research deals with a recent
ECJ decision on international jurisdiction for actions concerning directors’ or
shareholders’ liability (Osterloh-Konrad).
Such actions are often closely connected
to insolvency proceedings and therefore
raise questions about the scope of the
vis attractiva concursus under Art. 3(1)
EC Insolvency Regulation. Furthermore,
in cases where shareholders or directors
are made liable for a claim originating in
a contract between the insolvent company and the plaintiff, the demarcation line
between “matters relating to contract”
and “matters relating to tort” under the
rules of international jurisdiction comes
into play. In the ÖFAB case, the Court
made important clarifications on these
matters. In line with prior decisions on
related matters, it takes a functional approach: to determine which court has
jurisdiction, one has to look at the aim of
the action as a whole (including its procedural framework), not primarily at its
source in substantive law. This functional
perspective contributes to European harmonisation because it allows for identical
treatment of functionally equivalent legal
instruments even if their legal classification in different Member States diverges.
The article comments on the application
of this approach in the ÖFAB case and explores its relevance for cases of directors’
or shareholders’ liability under German
company and insolvency law.
c) Managers’ Duties in the Area of Tax
Planning
Corporate tax avoidance has probably
never received as wide attention as in
the past few years. It is no longer a topic
fiercely debated only by governments
and tax authorities. Through the work of
ZGR 41/2012, including Christine Osterloh-Konrad‘s article “Gefährdet “Empty
Voting” die Willensbildung in der Aktiengesellschaft?”
a number of non-governmental organisations, including religious ones, and an
unprecedented level of media coverage,
interest for the topic has reached the
general public and generated polemic debates, also in the academic community.
Opponents to aggressive tax-minimising
behaviour on the part of corporations,
especially multinationals, often appeal to
corporate social responsibility and the alleged need for corporations to pay their
fair share of taxes in each country where
they operate. Defenders, and in particular many corporate managers, claim legal
avoidance of taxes is consistent with and
required from managers’ duty to maximise shareholder value.
This topic was analysed with respect to
German law in an article authored by
the Department’s director (Schön). One
ongoing doctoral research work reaches
into the corporate laws in the United
Kingdom, United States, Germany and
Brazil, examining possible sources for a
57
Bianca Mostaccatto (left) presenting
first research findings during the poster
session of the Scientific Advisory Board
Meeting in July 2012.
duty to tax planning stemming from this
area of law and how the specific duties
owed by managers function to foster or
refrain corporate tax avoidance (Mostacatto). The results will shed some light on
how managers are legally bound to cause
the corporations organised under the
law of these countries to behave in the
tax realm, being of interest to managers
themselves, policy makers, regulatory
bodies, activists and non-governmental
organisations active in this area. It should
also serve as a starting point for further
in-depth analyses of the laws of other
countries in this respect, thus assisting
internal and international policy debates.
d) Issues of Capital Protection
One ongoing doctoral thesis deals with
capital protection of share premiums in
German, English and European Company
58
Law (Poschenrieder). When a company
issues shares, the investor has to pay
up the par value of those shares – share
capital – and is often asked for an additional capital contribution – share premium (“Agio”). The European Directive
on Capital Protection extends some of its
rules on the protection of share capital to
share premiums, but not all of them. This
narrow scope has been criticised in English legal writing as being incoherent and
irrational. English company law makes
very little difference both between the
legal treatment of share capital and share
premium, and between private limited
and public companies. German company
law takes a place somewhere between
English and European Company Law. For
public companies it brings into line most,
but not all of the rules on share capital
and share premium. For private companies it does not regulate premiums at
all. The doctoral thesis focuses on these
three very different approaches on the
regulation of share premiums and aims
to investigate the rationale behind every
approach and the coherence of the chosen system.
In 2009, the German legislator enacted
law concerning hidden contributions in
kind. One paper discusses the issues that
arose after enactment of the new provisions on hidden contributions in kind for
German stock-companies (section 27
subsection 3 of the German stock corporation law – AktG) (Andrianesis). Importantly, the provision states that shareholders do not have any voting rights in
the general meeting if the value of the
asset finally contributed falls “obviously”
short of the original obligation to con-
tribute in cash. The imposition of such
a vague legal term can have detrimental effects on the validity of the general
meeting resolutions. It is also doubtful
that the new provisions comply with the
European law. The permission to fulfil a
promise to contribute cash at the stage
of the formation of the company or for a
capital raise with a (hidden) contribution
in kind is not in line with the strict formal
provisions of the second directive about
contributions in kind.
e) Contracting Around Directors’
Liability
One doctoral research project that focused on the liability of directors of stock
corporations (Aktiengesellschaften) under German stock corporation law (AktG)
was completed during the reporting period (Eßwein). The research unfolds that
although there seems to exist little room
to arrange the liability of directors under
German stock corporation law, there is
the possibility of contractual solutions.
The work examines several contractual
arrangements which are interesting in
the context of designing or modifying
director’s liability. After comparing the
liability of directors under German stock
corporation law with the liability of directors of a Delaware Corporation under
DGCL, current proposals for reform are
examined and evaluated. Finally, the author develops a new system for indemnification under German stock corporation
law.
VII General Private Law
1. General Aspects
A comparative piece with a historical
dimension was a paper delivered at the
Obligations VII Conference in Hong Kong
in July 2014 (Häcker). The conference
was dedicated to exploring divergences
and convergences between the private
law of different common law systems
throughout the world. Drawing on the
experience of the European Ius Commune, the paper sought to identify the
kinds of factors which tend to make a
group of more or less closely related legal
systems converge or diverge, as the case
may be, and to think about those factors
in the context of the modern common
law. It concluded that the codification of
national law was, by and large, one of the
strongest forces for divergence, in that
it was likely to stifle mutual awareness
and intellectual exchange between the
systems. Against this background, harmonisation measures at the European
level, especially calls for the compilation
and enactment of a wholesale European
Civil Code, should be a matter of interest
not only for English and Irish lawyers, but
ought to command the attention of the
entire common law world. The balancing of private interests has
hitherto been seen as the primary task of
private law. However, one ongoing major
research project is aiming to show that
private law is better conceived of as a
tool which the legislator may use to regulate economy or society (Hellgardt). In
this respect, private law competes with
59
Archiv für die civilistische Praxis
213/2013 with Alexander Hellgardt‘s
article “Privatautonome Modifikation
der Regeln zu Abschluss, Zustandekommen und Wirksamkeit des Vertrags”.
criminal law and administrative law and
serves the public interest. A new concept of private law not only challenges
jurisprudential theories but also entails
important consequences for legislation
and legal practice.
2. Contract Law
a) Rules on Contract Formation,
Conclusion and Validation
One paper analyses whether under German law the rules on contract formation,
conclusion, and validity are mandatory
or can be changed by framework agreements or by private market rules – such
as stock exchange rules or the eBay user
agreement (Hellgardt). First, it is shown
that – even though a contract cannot
provide for the conditions of its own validity – the general rules of contract formation are not mandatory, i.e. they can
be changed by preceding agreements.
However, the limits how much one can
60
change the rules of contract formation
vary substantially, depending on the kind
of framework agreement. Framework
agreements between the parties of the
subsequent contracts are much more
restricted (e.g. by the rules governing the
permissible content of standard form contracts) than private market rules, which
are promulgated by an independent
third (though: private) party. The review
of such market rules follows procedures
known from the conflict-of-laws context.
This means that the reasonableness of
such rules is not part of the review but
only whether the results achieved violate
the state’s public policy (“ordre public”).
This is only the case if the rules lead to
a contract even though no responsibility
can be traced to either party. Also, it is
possible to use market rules to expand
the parties’ rights to rescind contracts
beyond the statutory provisions.
b) Termination of Loan Contracts
The principle of pacta sunt servanda
is one of the foundations of German
private law. Yet, in 1997, the Federal
Court of Justice overruled it by allowing
debtors to walk away from long-term,
fixed-interest-rate mortgages if they had
a legitimate interest in doing so, albeit
that they were not entitled to terminate
the mortgage according to the applicable
statutory provisions. The creditors were
compensated by means of an early repayment charge that was calculated according to the principles governing the law of
damages. Although this spectacular act
of judicial law making gave rise to fierce
criticism by many academics, the legisla-
tor embedded these principles in para.
490(2) of the German civil code only four
years later, in the context of a general
overhaul of the law of obligations. The
provision, however, was badly drafted
and increased rather than reduced legal
uncertainty, thus highlighting the dangers of a precipitated codification of the
results of judicial law making. The right
to terminate mortgages prematurely is
commonly regarded as an instrument of
consumer protection. However, this is
not line with the wording of para. 490(2),
which clearly shows that the scope of application of the right to early termination
is not limited to consumers, and which
requires a full compensation of any damage suffered by the creditor – making a
potential protection of the consumer
largely nominal. In particular after a
steep decline in interest rates, the early
repayment charge may easily amount to
more than 10 % of the outstanding debt.
Unsurprisingly, thus, consumer protection bodies routinely complain about
the provision and its application by the
courts. Against this background, it seems
more convincing to regard § 490(2) as
implementing the principle of “efficient
breach” – which is generally alien to
German private law – in the specific and
limited context of the early repayment
of long term fixed-interest-rate loan contracts. This qualification has implications
both for the scope of application of the
provision and for the calculation of the
early repayment charge. These findings
were presented at the 25th annual convention of young private law scholars
from Austria, Germany and Switzerland
and will be published in the conference
volume in 2015 (Röder).
Alexander Hellgardt
3. Damage Claims, Compensation and
Unjust Enrichment
a) Advisor’s Liability
A topic which was inspired by tax law but
which is deeply engrained in private law,
concerns the liability of tax and legal advisers for negligence with regard to the
prospective outcome of a case in court or
before a public authority. It is settled jurisprudence of the Federal Supreme Court
in Karlsruhe that the duties of the advisor have to be judged on an ex ante basis, taking into account the jurisprudence
of the day and the predicted reasoning
of the courts and authorities which were
presumed to deal with the case. It is also
settled jurisprudence that the existence
of a damages claim has to be judged on
an ex post basis, i.e. taking into account
the legal reasoning of the court which
is going to decide on the merits of the
damages claim. Any mismatch between
the ex ante view on a specific factual
and legal problem and the ex post view
on the same factual and legal problem
will go to the detriment of the claimant
as either there will be no negligence or
there will be no material damage. This
61
jurisprudence is heavily criticised in an
article forthcoming in a collected volume
(Schön) which shows that this is not only
bad law but also bad economics, given
the reduced incentive effect of liability
rules based on negligence.
b) Compensation for the “Use Value”
of Assets
The use value of an asset becomes relevant where the person holding legal
title to the asset and the person using
the asset are not identical. Where this
situation arises because of a lease or a
loan contract, the owner is compensated
by means of the rent or the interest that
both parties have agreed upon. If, however, the person using the asset is – for
whatever reason – not entitled to do
so, the question arises whether and to
what extent the rightful owner may – in
addition to the restoration of the asset
(where possible) – also claim compensation for its use value. In that respect, a
distinction has to be drawn between the
use that the owner would have made
of the asset had he or she not been deprived of it, and the use that the person
wrongly in possession of the asset actually has – or should have – made of it. For
the first position, the owner may claim
damages – but generally only if there is
an element of fault present. The situation is more complicated with regard to
the second position. As a comparative
analysis reveals, the solutions adopted
in France, the UK, the US and Germany
differ widely. How to make up for the use
value of an asset enjoyed by a person not
entitled to it is of particular relevance in
the event of the rescission or termination of a contract. Under the German
Civil Code, subject to the reason why a
contract is unwound, three different sets
of rules may be applicable that exhibit
some degree of inconsistency. In addition, the provisions of the German civil
code on use value compensation rely on
the out-dated concept that a certain
benefit or produce is inherent to a certain type of asset, for instance an apple
to an apple tree or a piglet to a sow. As
this ignores, inter alia, that many assets
are highly fungible and that the concrete
benefit derived from the use of an asset
might, to a large extent, be the result of
the ingenuity and the efforts of the person using it, the outcome of the statutory provisions is not always convincing.
A post-doctoral research project aims at
identifying criteria for a coherent and
rational system of use value compensation that could be implemented de lege
ferenda (Röder).
c) Unjust Enrichment
Erik Röder
62
Comparative research into core areas of
private law resulted in various publica-
tions surveying larger problem areas.
For instance, one was a contribution
to an international symposium on the
recent US Restatement Third: Restitution and Unjust Enrichment, examining
the Restatement’s position with regard
to the question of direct and indirect
enrichment at the claimant’s expense
in three-party scenarios (Häcker). The
key to solving many such cases lies in
identifying who has been enriched, i.e.
the proper defendant to an action, and
at whose expense the enrichment came,
i.e. the proper claimant to bring it. The
paper concludes that although the Restatement provided a whole host of examples dealing with specific situations,
there were a number of inconsistencies
in the theoretical approach underlying its
treatment, so that definitive structural
propositions could not be decuced.
4. Civil Law of Succession
On the private law side, a post-doctoral
research project on succession law is
currently mid-way (Häcker). It concerns
the law of legacies and the role they
play as mechanisms of estate planning.
Although many legacies today still take
the classic form of the testator leaving to
a relative or friend a specific asset which
forms part of his estate (and which upon
his death passes to the heir by virtue of
the principle of ‘universal succession’),
others are more in the nature of tools
intended to circumvent or modify particular rules which would otherwise hold
sway. Looking at the historical genesis of
this field of law – from its Roman origins
to developments in the 19th and 20th
(left to right): Birke Häcker, Thomas Poschenrieder, Chiara Balbinot, and Christine Watzinger, September 2013.
centuries – and using bequests as understood in common law jurisdictions as
a point of contrast and comparison, the
aim of the project is to better understand
the legal and doctrinal structures defining the three-party-relationship between
the testator, his heir and the legatee. In
this way, it seeks to elucidate the way
legacies operate in the broader context
and to explore the scope and boundaries
of the uses to which they may legitimately be put by modern drafting practice.
One article dealing with the law of
legacies in historical and comparative
perspective, which has already been
published (Häcker), is a contribution to
the volume marking the 60th birthday of
Professor Dr. Dr. h.c. mult. Reinhard Zimmermann, Director at the Max Planck Institute for Comparative and International
Private Law in Hamburg. It concerns an
early 18th century litigation arising from
the bequest by Christopher Codrington,
sometime Governor of Barbados, to All
Souls College in the University of Oxford
of his book collection as well as the sum of
£ 10,000 to enable the building of a new
library. Besides revealing a fascinating
63
story behind the scenes of the litigation,
the article explores the multi-facetted
legal background to the interpretative
question which the judge had to answer,
namely: did Codrington’s bequest relate
only to books which formed part of the
collection when the will was made, or did
it also extend to those acquired for him
by his agents right up to the time of his
death?
One research project deals in depth with
a particular legal problem concerning
the legal position of reversionary heirs
(Nacherben) under German inheritance
law (Osterloh-Konrad). If the testator appoints one or several reversionary heirs
under uncertain conditions, the identity
of the final heir often remains unclear
for a long time after the testator’s death,
sometimes for decades. During this period, the preliminary heir (Vorerbe) is
the rightful owner of the estate, but his
freedom to dispose is limited by various rights granted to the reversionary
heir. But – who is the reversionary heir?
Should everyone who might possibly
inherit have the same rights vis-à-vis
the preliminary heir or does the legal
position of a potential reversionary heir
depend on the probability of him becoming the final heir or on whether he
is appointed as a substitute for another
– the “primary” – reversionary heir? The
article points out why it is possible and
adequate to distinguish between different groups of potential heirs and analyses their respective legal positions. It
argues that the current approach to the
problem gives undue weight to legal definitions which actually only exist for the
sake of giving a name to what the testa-
64
tor wants. Instead, distinction between
different types of reversionary heirs can
only be grounded on the individual testator’s will and have to be justified by reference to his intentions.
Building on previous research activities
in the field of private law information
duties, one member of the Institute has
written a two-part article dealing with
information duties in inheritance law
(Osterloh-Konrad). In inheritance cases,
such duties are of particular importance
given the frequency of information asymmetries after a person’s death. The first
part of the article gives an overview of
the different legal sources of information
duties in inheritance cases. Its main focus
lies on duties founded on the principle of
good faith, which German courts have
frequently used to complement statutory instruments. The second part deals
with particular legal problems concerning information duties and with some
paradigmatic cases. One key aspect of
the analysis are the possibilities for the
plaintiff, or rather the lack thereof, to
verify the information given to him by
the defendant. German law widely fails
to adequately address the undoubtable
need for verification because, in most
cases, the plaintiff is not entitled to ask
for documental evidence concerning the
information given by the defendant.
The same member of the Institute has
updated her contributions to commentaries and a practitioners’ handbook
on issues of civil procedure raised by
inheritance cases (Osterloh-Konrad; see
Research Report 2010–2011, p. 60).
5. Various Comparative Pieces
One contribution expressly adopting a
comparative and historical viewpoint
was written for the volume commemorating the late Lord Rodger of Earlsferry,
formerly Lord of Appeal in Ordinary and
Justice of the recently established UK
Supreme Court (Häcker). Inspired by
his academic work on the relationship
between neighbouring land owners in
Roman law, it investigated the – sometime conflicting – principles in play when
the law determines disputes between
neighbours pertaining to trees standing
on or near the boundary of their land.
Questions such as who owns the tree,
the neighbours’ rights and duties with
respect to overhanging branches and the
fruit thereon, the problem of encroaching roots, and the right to light, all yielded a broad panorama of different civilian
and common law approaches. A number of smaller contributions on
specific decisions rounded off the Institute’s engagement with foreign private
law in the context of the wider research
agenda. Two took the form of case notes
published in the prestigious Law Quarterly Review, one in the area of wills and
succession, the other on the interplay of
contract and property law (Häcker). The
third arose from a decision of the UK
Supreme Court concerning the circumstances under which a voluntary settlement could be set aside on the basis that
it had been established under an erroneous assumption about its tax implications. The Court ruled that – in the particular circumstances of the case – there
had been a ‘sufficiently serious’ mistake
Student assistants currently at the Department include (left to right): Benedikt Lukas, Jan Lukas Rausch, and Vera
Gentner.
of tax law, such that it would be ‘unconscionable’ to let the disposition stand.
The rather vague criteria put forward by
this decision and their potential ramifications were subjected to a critical review
in an invited Current Legal Problems
lecture entitled ‘Mistaken Gifts after Pitt
v Holt’ at University College, London, in
February 2014, which was subsequently
published in the lecture series’ annual
volume (Häcker).
VIIIEuropean Monetary Union and
European Banking Law
The subject of the doctoral thesis that
was finalised in 2014 is the legal aspect
of the design of a payment system operated by the Euro system (Watzinger).
This thesis gives an outline of the historic and legal background of the Euro-
65
pean Monetary Union (EMU) and the
institutional framework with respect to
the common currency and the payment
system of the Euro system. Next, the
key economic concepts are presented
to provide an understanding of the economic consequences of the design and
operation of a payment system. Starting
from the foundations and the definitions
of the key terminology the functions of
payment systems, principles and risks
that occur in the course of operating a
payment system are explained. The experiences with cross border payments
since the 1930s are described to show
how the treatment of transactions has
developed. The legal framework of the
current payment system operated by
the Euro system, TARGET2, provides the
basis for a legal analysis. In the course of
cross border payments, so called TARGET2, balances can arise. For this reason,
TARGET2 has been criticised by German
economists. The following legal analysis,
especially regarding the TARGET2 imbalances and the consequences of a withdrawal or expulsion from the European
Union and EMU, touches on aspects of
European law, as well as German constitutional law. The analysis also takes the
jurisprudence of the ECJ and the German Constitutional Court into account.
The thesis concludes that the design of
TARGET2, and especially the TARGET2
balances, does not violate European law
or German constitutional law.
During the recent financial crisis, the
European Central Bank has played a
key role. Its response to the financial
problems of the member states led to a
number of unconventional measures in
66
the Euro area, which did not find the approval of all member states. As the current OMT-case shows, these new measures of the ECB can be subject to both
national and European judicial control. A
new doctoral research project therefore
tries to analyse the independence of the
ECB within the European and national
legal framework. The degree of judicial
control shall especially be a major part of
the research project (Dietz).
When the new European Account Preservation Order was still at the proposal
stage, one article subjected the Commission’s first draft to a critical examination
(Häcker). The Regulation establishes a
mechanism by which creditors who fear
that they may not be able to recover
cross-border debts can apply to court
for an interim freezing order. Funds on a
debtor’s bank accounts in other European countries are thus preserved pending
the outcome of civil proceedings. However, as originally drafted, the proposal
was extremely one-sided. In granting
applicants quick and efficient redress,
it failed to do justice to the legitimate
interests of the (actual or supposed)
debtor. There were also concerns of a
more fundamental constitutional nature,
especially about the extent to which
courts in one country should actually be
allowed to make what are effectively enforcement orders pertaining to another
jurisdiction. The Regulation, which was
subsequently amended to take greater
account of the debtor’s interests, came
into force in mid–2014. Junior research fellows (doctoral students) of the Department in May 2015.
Front row (left to right): Leopoldo Parada, Angelika Meindl-Ringler, Deborah
Fries, Dina Lijic, Marta Oliveros Castelon, Martina Sunde, Bianca Mostacatto.
Back row (left to right): Bernd Fluck, Stefan Kreutzer, Šime Jozipović, Christian
Sternberg.
67
B Publications, Lectures, Teaching, and
Awards
IPublications
Philipp Aigner
Books
Aigner, Philipp. Wegfall der Einkunftsquelle
bei den Kapitaleinkünften (§ 20 EStG
n.F.). Die steuerliche Behandlung der
Gesellschaftsinsolvenz und des Ausfalls der
Kapitalforderung, insbesondere des Gesellschafterdarlehens. Boorberg, Stuttgart
2013, 260 p.
Journal Articles and Notes
Andrianesis, Anastasios. Report on the
Amendments to the Germany KapMuG.
EEmpD 2012, No. 4, 1019-1021.
Andrianesis, Anastasios. Report on Latest
German Legislation on Financial Recovery
of Financial Groups and Institutes. EEmpD
2013, No. 3, 785-786.
Andrianesis, Anastasios. Cash Settled Equity
Swaps and the Mandatory Bid: The Civil Law
Sequel. EEmpD 2014, No. 4, 954-961.
Forthcoming
Andrianesis, Anastasios. Tax Law of Hydrocarbons. In: Hydrocarbons Law, Nomiki
Bibliothiki, forthcoming.
68
Hugh Ault
Ault, Hugh. Some Reflections on the OECD
and the Sources of International Tax Principles. Tax Notes International 70/2013,
No. 12, 1195-1213 and Working Paper of
the Max Planck Institute for Tax Law and
Public Finance No. 2013-03 (ssrn.com/
abstract=2287834).
Ault, Hugh, Wolfgang Schön, and Stephen
E. Shay. Base Erosion and Profit Shifting: A
Roadmap for Reform. Bulletin for International Taxation 68/2014, No. 6-7, 275-279.
Andreas Bakrozis
Contributions in Collected Volumes
Bakrozis, Andreas and Natalia Paxinou.
Eigen- und Fremdkapital im Steuer- und
Gesellschaftsrecht Griechenlands. In: Eigenkapital und Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik (MPI Studies in Tax Law and Public
Finance, Vol. 3), (ed.) W. Schön, Springer,
Heidelberg 2013, 433-481.
Chiara Balbinot
Forthcoming
Balbinot, Chiara. Review of: M. Poggioli,
L’imposizione confiscatoria, tra valutazione
astratta e misurazione concreta: alcune
riflessioni in prospettiva dialogica (Rivista
di diritto tributario 24/2014, No. 2, Parte I,
193-229). StuW 92/2015, No. 1, 98-99.
Balbinot, Chiara and Philipp Aigner. Die
Besteuerung des Stillhalters von Optionsgeschäften nach § 20 EStG. DStR 53/2015, No.
5, 198-204.
Tobias Beuchert
Books
and Public Finance, Vol. 3), (ed.) W. Schön,
Springer, Heidelberg 2013, 483-540.
Discussion Papers
Boer, Martin J. A Few Comments on the
CCTB-Directive. Working Paper, 2012
(http://ssrn.com/abstract=2012276).
Beuchert, Tobias. Anzeigepflichten bei Steuergestaltungen. Dr. Otto Schmidt, Cologne
2012, 401 p.
Sara E. Dietz
Dietz, Sara E. and Thomas Streinz. Das
Marktzugangskriterium in der Dogmatik der
Grundfreiheiten, EuR 50/2015, No. 1, 50-72.
Osterloh-Konrad, Christine and Tobias
Beuchert. Anzeigepflichten bei Steuergestaltungen in Deutschland – Zu den aktuellen
Überlegungen des Bundesrates aus rechtspolitischer und rechtlicher Sicht.
IStR 23/2014, No. 18, 643-650.
Beuchert, Tobias and Philipp Redeker. Eigenund Fremdkapital im Steuer und Gesellschaftsrecht Deutschlands. In: Eigenkapital
und Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik
(MPI Studies in Tax Law and Public Finance,
Vol. 3), (ed.) W. Schön, Springer, Heidelberg
2013, 289-371.
Martin J. Boer
Boer, Martin J. The Introduction of a Fair
and Efficient Regime for Fiscal Unity that
Can Prevent Bankruptcy of Insolvent and
Loss-Suffering Companies. 2012, e-Journal
University of Groningen/RechtenOnline.
Forthcoming
Andreas Eggert
Eggert, Andreas. Behandlung von Anteilen
an transparenten Unternehmen im Rahmen
der GKKB. ISR 2/2013, No. 9, 304-310.
Mauritz von Einem
von Einem, Mauritz. The EU Interest and
Royalties Directive: Current Issues. In: Tax
Aspects of Research and Development
within the European Union (eds.) W. Nykiel
and A. Zalasinski, LEX, Warszawa 2014, 147167.
Astrid Erker (Roesener)
Erker, Astrid. Die Business Judgment Rule
im Haftungsstatut des Insolvenzverwalters.
ZInsO 50/2012, No. 6, 199-204.
Boer, Martin J. Eigen- und Fremdkapital im
Steuer- und Gesellschaftsrecht der Niederlande. In: Eigenkapital und Fremdkapital Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik (MPI Studies in Tax Law
Erker, Astrid. Zinsschranke und gesellschaftsrechtliche Treuepflicht. DStR
50/2012, No. 10, 498-500.
Publications, Lectures, Teaching, and Awards
69
69
Roesener, Astrid and Sabine Heidenbauer.
Eigen- und Fremdkapital im Steuer- und Gesellschaftsrecht Österreichs. In: Eigenkapital
2013, 541-592.
Deborah Fries
Forthcoming
Fries, Deborah. Review of: Rosenbloom/
Noked/Helal: The Unruly World of Tax: A
Proposal for an International Tax Cooperation Forum (Florida Tax Review 15/2014, No.
2, 57). StuW 92/2015, No. 1, 98.
Juan Franch Fluxà
Franch Fluxà, Juan. Tributación y deducción de los intereses transfronterizos entre
empresas asociadas (Comentario a la STJUE
de 21 de julio de 2011, C-397/09). Noticias
de la Unión Europea 66/2012, No. 330, 151156.
Christian Gárate González
Books
Gárate González, Christian. Research &
Development & Innovation Fiscal Incentive
Provisions. Ludwig-Maximilians-Universität
München, Munich 2014, 565 p.
Andreas Gerten
Books
Gerten, Andreas. Angemessenheit und
Steuern - Verdeckte Einkommensverwendung bei Kapitalgesellschaften im internationalen Vergleich, Schriften zum Gesell-
70
schafts-, Bilanz- und Unternehmensteuerrecht. SGBU 17, Peter Lang, Frankfurt 2014,
357 p.
Gerten, Andreas, Maximilian Haag, and
Daniel Kornack. Eigen- und Fremdkapital im
Steuer- und Gesellschaftsrecht der Vereinigten Staaten von Amerika. In: Eigenkapital
2013, 775-833.
Birke Häcker
Books
Häcker, Birke. Consequences of Impaired
Consent Transfers: A Structural Comparison
of English and German Law. Hart Publishing,
Oxford 2013, 408 p. First published in paperback by Mohr Siebeck, Tübingen 2009.
Elliott, Steven, Birke Häcker and Charles
Mitchell (eds.). Restitution of Overpaid Tax.
Hart Publishing, Oxford 2013, 366 p.
Häcker, Birke. Die geplante EU-Verordnung
zur grenzüberschreitenden vorläufigen
Kontopfändung – Eine kritische Analyse.
Wertpapier-Mitteilungen – Zeitschrift für
Wirtschafts- und Bankrecht (WM) 66/2012,
No. 46, 2180-2186.
Häcker, Birke. A Case Note on All Souls
College v. Cod[d]rington (1720). RabelsZ
76/2012, No. 4, 1051-1077.
Häcker, Birke. The Effect of Rescission on
Bona Fide Purchase. Case Note on the Court
of Appeal Decision in Independent Trustee
Services Ltd v. GP Noble Trustees Ltd [2012]
EWCA Civ 195. Law Quarterly Review (LQR)
128/2012, No. 4, 493-497.
Häcker, Birke. Thy Will Be Done. Law
Quarterly Review (LQR) 130/2014, No. 3,
360–365.
Häcker, Birke. Mistaken Gifts after Pitt v
Holt. Current Legal Problems 67/2014,
No. 1, 333-372.
Häcker, Birke. Das englische Common Law: Eine Einführung. JuS 54/2014, No. 10, 872-876.
Häcker, Birke. ‘Public Law Restitutionary
Claims’: The German Perspective. In: Restitution of Overpaid Tax, (eds.) S. Elliott, B.
Häcker, and C. Mitchell, Hart Publishing,
Oxford 2013, 239-271.
Häcker, Birke. Introduction. In: Restitution
of Overpaid Tax, (eds.) S. Elliott, B. Häcker,
and C. Mitchell, Hart Publishing, Oxford
2013, 3-20.
Häcker, Birke. Direct and Indirect Enrichment at the Claimant’s Expense in ThreeParty Cases. In: The Restatement Third:
Restitution and Unjust Enrichment – Critical
and Comparative Essays, (eds.) C. Mitchell
and W. Swadling, Hart Publishing, Oxford
2013, 31-57.
Häcker, Birke. Trees and Neighbours. In:
Judge and Jurist – Essays in Memory of Lord
Rodger of Earlsferry, (eds.) A. Burrows, D.
Johnston, and R. Zimmermann, OUP, Oxford
2013, 591-618.
Forthcoming
Häcker, Birke. Divergence and Convergence
in the Common Law – Lessons from the Ius
Commune, LQR, forthcoming.
Häcker, Birke. Minority and Unjust Enrichment Defences, Contribution to Conference
Volume: Defences in Unjust Enrichment,
(eds.) A. Dyson, J. Goudkamp, and F.
Wilmot-Smith, Hart Publishing, Oxford,
forthcoming.
Caroline Heber
Daxkobler, Katharina, Kasper Dziurdz, Caroline Heber, and Elisabeth Pamperl. Tagungs-
bericht zum IFA-Kongress 2013 in Kopenhagen. ÖStZ 66/2013, No. 22, 526-535.
Heber, Caroline. Seminar A: Mehrwertsteuerliche Behandlung von Ausgliederung
und Zusammenschlüssen zur Kostenteilung.
IStR 23/2014, No. 19, 686-691. Heber, Caroline. Kooperationen als Teil der
nicht-wirtschaftlichen Sphäre. UR 63/2014,
No. 24, 957-969.
Heber, Caroline and Christian Sternberg.
Over-the-Counter Derivative Markets in the
Light of the EMIR Clearing Obligations and
the Financial Transaction Tax. Derivatives
and Financial Instruments (DFI) 16/2014,
No. 3, 107-116.
German version:
EMIR Clearing Pflicht und die Finanztransaktionssteuer. RdF 4/2014, No. 3, 211-220.
Legal Interpretation of Tax Law in Germany. In: Legal Interpretation of Tax Law (Series
on International Taxation; 46), (eds) R.
van Brederode and R. Krever, Kluwer Law
International, Alphen aan den Rijn 2014,
163-189.
Discussion Papers
Market Infrastructure Regulation and the
Financial Transaction Tax. Working Paper
of the Max Planck Institute for Tax Law and
Public Finance No. 2014-07 (http://ssrn.
com/abstract=2433009).
Sabine Heidenbauer
Heidenbauer, Sabine and Astrid Roesener.
Eigen- und Fremdkapital im Steuer- und Gesellschaftsrecht Österreichs. In: Eigenkapital
71
71
2013, 541-592.
Alexander Hellgardt
Hellgardt, Alexander. Europarechtliche
Vorgaben für die Kapitalmarktinformationshaftung – de lege lata und nach Inkrafttreten der Marktmissbrauchsverordnung.
AG 57/2012, No. 5, 154-168.
Hellgardt, Alexander. Praxis- und Grundsatzprobleme der BGH-Rechtsprechung zur
Kapitalmarktinformationshaftung – Zugleich
Besprechung des IKB-Urteils des BGH v.
13.12.2011, XI ZR 51/10. DB 65/2012, No.
12, 673-678.
Hellgardt, Alexander. Von der bürgerlichrechtlichen Prospekthaftung zur Informationshaftung beim Vertrieb von Vermögensanlagen – Eine Nachlese zum „Rupert
Scholz“-Urteil des BGH vor dem Hintergrund
des neuen Vermögensanlagegesetzes. ZBB
24/2012, No.2, 73-88.
Hellgardt, Alexander et al. Auditor Independence at the Crossroads – Regulation
and Incentives. EBOR 13/2012, No. 1, 89101.
Hellgardt, Alexander. The Notion of Inside
Information in the Market Abuse Directive: Geltl. Common Market Law Review
50/2013, No. 3, 861-874.
Hellgardt, Alexander. Privatautonome
Modifikation der Regeln zu Abschluss,
Zustandekommen und Wirksamkeit des
Vertrags – Möglichkeit und Grenzen der
Abdingbarkeit der §§ 116 ff., 145 ff. BGB
innerhalb von Geschäftsbeziehungen und
auf privaten Marktplätzen. AcP 213/2013,
No. 5-6, 760-825.
Hellgardt, Alexander. Law and Development: Vom Einfluss des Zivilrechts auf die
wirtschaftliche Entwicklung. In: Realitäten
des Zivilrechts. Grenzen des Zivilrechts,
72
Jahrbuch Junger Zivilrechtswissenschaftler
2011, (eds.) P. Kreutz, N. Renftle, E. Faber, D.
Arndt, N. Huber, H.-M. Schellhase, and M.
Steuer, Richard Boorberg, Stuttgart 2012,
97-118.
Hellgardt, Alexander. Mandatory Disclosure
(Securities Markets). In: Max Planck Encyclopedia of European Private Law, Vol. II., (eds.)
J. Basedow, K. J. Hopt, and R. Zimmermann,
Oxford, OUP, 2012, 1118-1121.
Hellgardt, Alexander. Prospectus Liability.
In: Max Planck Encyclopedia of European
Private Law, Vol. II., (eds.) J. Basedow, K. J.
Hopt, and R. Zimmermann, Oxford, OUP,
2012, 1384-1387.
Hellgardt, Alexander. Regulierung mittels
Privatrechts / Regulation by Means of Private Law. 2012 Yearbook of the Max Planck
Society (Research Report, http://www.mpg.
de/4673878/Regulierung_Privatrecht).
Hellgardt, Alexander. Comparing Apples
and Oranges? Public, Private, Tax, and Criminal Law in Financial Markets Regulation.
In: Legal Challenges in the Global Financial
Crisis: Bail-outs, the Euro and Regulation,
(eds.) W.-G. Ringe and P. M. Huber: Hart
Publishing, Oxford 2014, 157-176, and
Working Paper of the Max Planck Institute
for Tax Law and Public Finance No. 2012-04
Ringe, Wolf-Georg and Alexander Hellgardt.
Transnational Issuer Liability After the
Financial Crisis: Seeking a Coherent Choice
of Law Standard. In: Extraterritoriality and
Collective Redress, (eds.) D. Fairgrieve and E.
Lein, OUP, Oxford 2012, 401-430.
Interviews
Hellgardt, Alexander. Recht als Exportdienstleistung. Kathrin M. Möslein im
Interview mit Alexander Hellgardt. In: Law
as a Service – Recht als Dienstleistung: Strategischer Produktivitätsfaktor unternehmerischer Innovation?, (eds.) K. M. Möslein, J.
M. Leimeister, F. Möslein, and R. Reichwald,
Leipzig 2012, 14-15.
Carsten Hohmann
Hohmann, Carsten and Lukas Müller. Eigenund Fremdkapital im Steuer- und Gesellschaftsrecht der Schweiz. In: Eigenkapital
2013, 593-696.
Yasmin Holm
Holm, Yasmin. Tagungsbericht zur 13. IStRJahrestagung 2013. IStR 22/2013, No. 21,
III-IV.
Holm, Yasmin and Felix Grollmann. Steuerhistorisches Symposium der Deutschen
Steuerhistorischen Gesellschaft e.V.. StuW
43/2013, No.4, 383-384.
Marion Hombach
Books
Hombach, Marion. Sperrklauseln im
Europäischen Steuerrecht. Nomos, BadenBaden 2013, 419 p.
Alexander Jehlin
Books
Jehlin, Alexander. Die Zinsschranke als
Instrument zur Missbrauchsvermeidung
und Steigerung der Eigenkapitalausstattung.
Tübinger Schriften zum Staats- und Verwaltungsrecht, Vol. 93, Duncker & Humblot,
Berlin 2013, 267 p.
Jehlin, Alexander. Die Quellenbesteuerungspolitik für grenzüberschreitende
Zinszahlungen zwischen Industrie- und
Entwicklungsländern – mit besonderer Betrachtung der BRIC-Staaten. In: Eigenkapital
2013, 155-193.
Šime Jozipović
Jozipović, Šime. Economic, Constitutional
and Normative Aspects of the Determination Process of Strategic Investments in
Croatia. Law Review of the Faculty of Law,
University Split 50/2013, No. 4, 917-936.
Jozipović, Šime. Developments in the CFC
Legislation Regarding Croatia. European Tax
Studies 2013, No.1, 1-19.
Jozipović, Šime and Nikola Mijatović. The
Minimum Taxation in Cases of Tax Losses of
German Companies. Croatian Law Review
13/2013, No. 6, 51-61.
Jozipović, Šime and Nikola Mijatović. Die
Bedeutung des neuen kroatischen Finanzrechts für die Angleichung an die fiskalischen Standards der EU. Osteuropa-Recht
60/2014, No. 2, 231-245.
Discussion Papers
Jozipović, Šime. State Aid Procedure Law in
Tax Matters and the Croatian Accession to
the EU. Collected Papers of the Law Faculty
of the University of Rijeka 35/2013, No. 2,
625-60.
Forthcoming
Jozipović, Šime. The Transformation of
Creditors’ Claims into Shares in the (Bankruptcy-)Debtors – Comparative Notes and
Constitutional Issues. Collected Papers of
Zagreb Law Faculty, forthcoming.
Jozipović, Šime. Fines and Civil Mechanisms
of Redress Against Cartels in the Energy
Sector. Law Review of the Faculty of Law,
University Split, forthcoming.
73
73
Leif Klinkert
Marquart, Christian. Steuerinduzierte
Fremdfinanzierung von Unternehmen und
Wege der Begrenzung des Zinsabzugs. In:
Eigenkapital und Fremdkapital - Steuerrecht
- Gesellschaftsrecht - Rechtsvergleich Rechtspolitik (MPI Studies in Tax Law and
Public Finance, Vol. 3), (ed.) W. Schön,
Marquart, Christian and Leif Klinkert. Aus der
Praxis: Anspruchsverfolgung einer Erbengemeinschaft. JuS 52/2012, No. 11, 989-993.
Karin E. M. Kopp
Kopp, Karin E. M. Eigenkapital, Fremdkapital
und hybride Finanzierungen im internationalen Steuerrecht. In: Eigenkapital und
Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik (MPI
Studies in Tax Law and Public Finance, Vol.
3), (ed.) W. Schön, Springer, Heidelberg
2013, 835-876.
Stefania Martinengo
Martinengo, Stefania. Il federalismo fiscale
municipale e il difficile processo di autonomia degli enti locali. Studium Iuris 19/2013,
No. 5, 550-557.
Angelika Meindl-Ringler
Nadja Lagdali
Osterloh-Konrad, Christine and Nadia Lagdali. Eigen- und Fremdkapital im Steuer- und
Gesellschaftsrecht Frankreichs. In: Eigenkapital und Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik (MPI Studies in Tax Law and Public
Christian Marquart
Books
Marquart, Christian. Zinsabzug und steuerliche Gewinnallokation - Rechtsvergleichende
Untersuchung und rechtspolitischer
Vorschlag. Nomos, Baden-Baden 2013, 476 p.
Marquart, Christian. Promotionsstudium
am Max-Planck-Institut für Steuerrecht
und Öffentliche Finanzen in München. JuS
52/2012, No. 8, XXX.
74
Meindl, Angelika. Rechtsschutz gegen
rückwirkende Steuergesetze durch die
Europäische Menschenrechtskonvention –
ein Vergleich mit der Rechtsprechung zum
Grundgesetz. StuW 90[43]/2013, No. 2,
143-155.
Forthcoming
Meindl-Ringler, Angelika. Review of: Yair
Listokin: Taxation and Marriage: A Reappraisal (Tax Law Review 67/2014, No. 2,
185-210). StuW 92/2015, No. 1, 99-100. Toshiko Miyamoto
Miyamoto, Toshiko. Some Issues on
Reduced Tax Rate in Consumption Tax. Denmark, Zeiken 30/2014, No. 2, 53-58.
Miyamoto, Toshiko. Case Study on Application of Contribution Profit Split Method in
Transfer Pricing: Tokyo District Court, Judgment from April 27, 2012. Zeiken 30/2014,
No 4, 166-170.
Miyamoto, Toshiko. Case Study on Application of Estimated Tax Provision in Transfer
Pricing: Tokyo High Court, Judgment from
March 14, 2013. The hogaku seminar
zoukan, sokuhouhanreikaisetsu 15/2014,
233-236.
Forthcoming
Miyamoto, Toshiko. Cross-Border Reorganization and Exit Taxes in the EU. The
Ritsumeikan Economic Review 63/2015, No.
5-6, 1-13.
Bianca Mostacatto
Mostacatto, Bianca. Eliminating Regulatory Reliance on Credit Ratings: Restoring
the Strength of Reputational Concerns.
Stanford Law & Policy Review 24/2013,
No. 1, 99-142 and Working Paper of the
Max Planck Institute for Tax Law and Public
Finance No. 2012-07 (http://ssrn.com/
abstract=2120395).
Mostacatto, Bianca. Die Pflichten von
Managern bei der Steuerplanung: Eine
rechtsvergleichende Untersuchung / Managers’ Duties with Regard to Tax Planning:
A Comparative Analysis In: 2014 Yearbook
of the Max Planck Society (Research
Report, http://www.mpg.de/7732681/
JB_2014?c=8236817).
Alice Niemann
Books
Anwendung des § 42 AO. Peter Lang, Frankfurt 2012, 380 p.
Oliveros Castelon, Marta and Gerd W.
Rothmann. Hinzurechnungsbesteuerung in
Brasilien – Die wichtigsten Fälle zur
brasilianischen CFC-Gesetzgebung im Überblick. Recht der Internationalen Wirtschaft
58/2012, No. 11, 746-751.
Oliveros Castelon, Marta. Eigen- und
Fremdkapital im Steuer- und Gesellschaftsrecht Brasiliens. In: Eigenkapital und Fremdkapital - Steuerrecht - Gesellschaftsrecht
- Rechtsvergleich - Rechtspolitik (MPI Studies in Tax Law and Public Finance, Vol. 3),
(ed.) W. Schön, Springer, Heidelberg 2013,
195-288.
Oliveros Castelon, Marta. Einkünfte aus
grenzüberschreitenden Dienstleistungen:
Welcher Staat darf besteuern?/ Income
from Cross-Border Services: Which Country
Has the Right to Tax it? In: 2013 Yearbook
JB_2013?c=7291742).
Oliveros Castelon, Marta. Taxing CrossBorder Services. In: Newsletter of the Max
Planck Institute for Tax Law and Public
Finance, 01/2013 (http://www.tax.mpg.de/
files/pdf2/2103-07-22_Interaktiv1.pdf).
Oliveros Castelon, Marta. CASO JCPALEMANHA: Qualificação de juros sobre o
capital próprio pelo Tribunal Federal das
Finanças na Alemanha (Bundesfinanzhof).
In: Tributação internacional: análise de
casos v. 2, (ed.) L.F.d.M e. (Org.) Castro,
Leonardo Freitas de Moraes, MP, São Paulo
2014, 93-124.
Niemann, Alice. Der allgemeine Missbrauchsvorbehalt nach der Rechtsprechung
des EuGH und seine Auswirkungen auf die
75
75
Cihat Öner
Öner, Cihat. Legal Nature of Advance Pricing
Agreements under Turkish Law: A Comparative Analysis, Intertax 40/2012, No. 8/9,
503-513.
Osterloh-Konrad, Christine. Kommentierung
Anh zu § 2303 BGB, §§ 27, 28, 239-250,
253, 254, 256, 1066 ZPO. In: Fachanwaltskommentar Erbrecht, (ed.) A. Frieser,
Luchterhand, Köln 2013, 4/2013, 872-873,
1409-1445, 1464-1465.
Osterloh-Konrad, Christine. Gefährdet
„Empty Voting“ die Willensbildung in der
Aktiengesellschaft? Überlegungen zur Proportionalität zwischen Stimmrechtseinfluss
und wirtschaftlicher Betroffenheit der Aktionäre. ZGR 41/2012, No. 1, 35-80.
Osterloh-Konrad, Christine. Rechtsgrundlagen für Informationsansprüche im Erbrecht.
ErbR 7/2012, No. 10, 299-306.
Osterloh-Konrad, Christine. Informationsansprüche im Erbrecht: Besondere Fragestellungen. ErbR 7/2012, No. 11, 326-334.
Osterloh-Konrad, Christine. Tagungsbericht
8. Deutscher Erbrechtstag. ErbR 8/2013, No.
6, 170-172.
Osterloh-Konrad, Christine. Anmerkung zu
EuGH v. 18.07.2013 – C-147/12. JZ 69/2014,
No. 1, 44-47.
Osterloh-Konrad, Christine. Tagungsbericht
7. ErbR-Tagung, München, 7. Oktober 2013.
ErbR 9/2014, No. 1, 22-24.
Osterloh-Konrad, Christine and Tobias
Beuchert. Anzeigepflichten bei Steuergestaltungen in Deutschland – Zu den aktuellen Überlegungen des Bundesrates aus
rechtspolitischer und rechtlicher Sicht. IStR
23/2014, No. 18, 643-650.
Schön Wolfgang, Andreas Bakrozis, Johannes Becker, Tobias A. Beuchert, Martin
Boer, Nadja Dwenger, Andreas Gerten,
Maximilian Haag, Sabine Heidenbauer,
Carsten Hohmann, Alexander Jehlin, Karin
E. M. Kopp, Daniel Kornack, Nadia Lagdali,
Christian Marquart, Lukas Müller, Marta
76
Castelon, Christine Osterloh-Konrad, Natalia
Paxinou, Carlo Pohlhausen, Philipp Redeker,
Erik Röder, and Astrid Roesener. Debt and
Equity in Domestic and International Tax
Law – A Comparative Policy Analysis. British
Tax Review (BTR) 59/2014, No. 2, 146-217
and Working Paper of the Max Planck Institute for Tax Law and Public Finance 2014-09
Osterloh-Konrad, Christine and Nadia Lagdali. Eigen- und Fremdkapital im Steuer- und
Gesellschaftsrecht Frankreichs. In: Eigenkapital und Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik (MPI Studies in Tax Law and Public
Forthcoming
Osterloh-Konrad, Christine. Fiat voluntas!
Der Schutz potentieller Rechtsnachfolger bei
der Anordnung von Vor- und Nacherbschaft,
AcP 2015, forthcoming.
Leopoldo Parada
Parada, Leopoldo. Is it Debt or Is it Equity?
The Problem with Using Hybrid Financial Instruments. Tax Notes International 74/2014,
No. 4, 347-356.
Parada, Leopoldo. Lessons Learned From
the Swiss Julius Baer Case. Tax Notes International 74/2014, No. 13, 1217-1224.
Forthcoming
Parada, Leopoldo. Intergovernmental
Agreements and the Implementation of
the Foreign Account Tax Compliance Act
(FATCA) in Europe, World Tax Journal (IBFD),
forthcoming.
Federica Pitrone
Pitrone, Federica. Il federalismo fiscale municipale e il difficile processo di autonomia
degli enti locali. Studium Iuris 19/2013,
No. 5, 550-557.
Carlo Pohlhausen
Books
Pohlhausen, Carlo. Unternehmensfinanzierung am Kapitalmarkt in den arabischen
Staaten: eine rechtsvergleichende Analyse
von Aktien-, Anleihe- und Hybridemissionen
am Beispiel Ägyptens, der Vereinigten
Arabischen Emirate, Saudi-Arabiens und
Jordaniens. StudIPR 309, Mohr Siebeck,
Tübingen 2014, XXXVII + 796 p.
Pohlhausen, Carlo and Erik Röder. Eigenund Fremdkapital im Steuer- und Gesellschaftsrecht des Vereinigten Königreichs. In:
Eigenkapital und Fremdkapital – Steuerrecht
– Gesellschaftsrecht - Rechtsvergleich –
Rechtspolitik (MPI Studies in Tax Law and
Ponomareva, Karina. Probleme der Steuersouveränität in der Rechtspraxis des
EuGH zu Fragen der direkten Besteuerung.
Aktuelle Probleme des russischen Rechts
3/2015, 151-155.
Ponomareva, Karina. Allgemeine Fragen der
Steuerharmonisierung in der EU. Informationsblatt der Staatlichen Universität Omsk,
Serie Recht 3/2015.
Ponomareva, Karina. Aktuelle Probleme der
Steuerharmonisierung in der EU. Materialien zur internationalen wissenschaftspraktischen Konferenz “Aktuelle Fragestellungen
im öffentlichen und privaten Recht”. Minsk,
Weißrussland 2015.
Philipp Redeker
Books
Redeker, Philipp. Beschaffenheitsbegriff und
Beschaffenheitsvereinbarung beim Kauf,
Verlag C.H. Beck, Munich 2012, 281 p.
Tobias Beuchert and Philipp Redeker. Eigenund Fremdkapital im Steuer und Gesellschaftsrecht Deutschlands. In: Eigenkapital
2013, 289-371.
Erik Röder
Karina Ponomareva
Books
Forthcoming
Schön, Wolfgang and Erik Röder. Zukunftsfragen des deutschen Steuerrechts II. MPI
Studies in Tax Law and Public Finance,
Volume 4, Springer Verlag, Heidelberg 2014,
IX + 148 p.
Ponomareva, Karina. Rechtspositionen
des EuGH zu Fragen der direkten Steuern.
Informationsblatt der Staatlichen Universität
Omsk, Serie Recht 1/2015. 98-103. Ponomareva, Karina. Europäische Determinanten des nationalen Steuerrechts. Steuern und Besteuerung 2015, No. 2, 157-166.
Röder, Erik. Proposal for an Enhanced CCTB
as Alternative to a CCCTB with Formulary
77
77
Apportionment. World Tax Journal 4/2012,
Finance No. 2012-01(http://ssrn.com/abstract=2012640).
Röder, Erik. Zur Verfassungswidrigkeit der
Mindestbesteuerung (§ 10d Abs. 2 EStG)
und der Beschränkung des Verlustabzugs
nach § 8c KStG. StuW 89[42]/2012, No. 1,
18-32.
Röder, Erik. Diskussionsbericht zu den Referaten von Peter O. Mülbert, Peter Clouth,
Hans Christoph Grigoleit und Petra BuckHeeb. ZHR 177/2013, No. 2/3, 344-348.
Röder, Erik and Malcom Gammie. Taxation
of Financial Transactions. Bulletin for International Taxation 67/2013, No. 10, 529-535.
Röder, Erik. Die Kommanditgesellschaft
im Rechtsvergleich: Hintergründe der unterschiedlichen Karriere einer Rechtsform.
RabelsZ 78/2014, No. 1, 109-154.
Röder, Erik. Co-ordination of Corporate
Exit Taxation in the Internal Market and
Beyond. British Tax Review (BTR) 2014,
Finance No. 2014-22. (http://ssrn.com/
abstract=2537465).
Law – A Comparative Policy Analysis. British
Tax Review (BTR) 59/2014, No. 2, 146-217
78
Pohlhausen, Carlo and Erik Röder. Eigenund Fremdkapital im Steuer- und Gesellschaftsrecht des Vereinigten Königreichs. In:
Röder, Erik. Germany: The Wagner-Raith
(C-560/13) and Grünewald (C-559/13)
Cases. In: ECJ – Recent Developments in
Direct Taxation 2013 (Series on International
Tax Law; 83), (eds.) M. Lang, P. Pistone, J.
Schuch, C. Staringer, and A. Storck, Linde,
Vienna 2014, 63-82.
Forthcoming
Röder, Erik. Die vorzeitige Beendigung
von Darlehensverträgen gegen Vorfälligkeitsentschädigung im Spannungsfeld von
Rechtsfortbildung und Kodifizierung. Jahrbuch Junger Zivilrechtswissenschaftler 2014,
forthcoming.
Jonathan Schindler
Schindler, Jonathan. Rechtliche Gestaltungsmöglichkeiten der Hofübergabe. ErbR
8/2013, No. 11, 334-341.
Wolfgang Schön
Books
Schön, Wolfgang and Kai A. Konrad (eds.).
Fundamentals of International Transfer Pricing in Law and Economics. MPI Studies in
Tax Law and Public Finance, Vol. 1, Springer,
Heidelberg 2012, XIII + 304 p.
Bachmann, Gregor, Horst Eidenmüller,
Andreas, Engert, Holger Fleischer, and Wolfgang Schön (eds.). Rechtsregeln für die geschlossene Kapitalgesellschaft. ZGR, Special
Vol. 18, De Gruyter, Berlin 2012, 235 p.
English version:
Bachmann, Gregor, Horst Eidenmüller,
Andreas, Engert, Holger Fleischer, and Wolfgang Schön. Regulating the Closed Corporation. ECFR, Special Vol. 4, De Gruyter, Berlin
2013, 265 p.
Schön, Wolfgang, Isabelle Richelle, and
Edoardo Traversa (eds.). Allocating Taxing
Powers within the European Union. MPI
2, Springer, Berlin 2013, XI + 220 p.
Schön, Wolfgang. Leitideen des Steuerrechts oder: Nichtwissen als staatswissenschaftliches Problem. StuW 90[43]/2013,
No. 4, 289-297.
Schön, Wolfgang. Prof. Dr. Franz Dötsch
tritt in den Ruhestand. FR 96/2014, No. 4,
145-146.
Schön, Wolfgang. Ein Steuerrecht für die
Wissensgesellschaft. FR 96/2014, No. 3,
93-97.
Schön, Wolfgang (eds.). Eigenkapital und
Fremdkapital - Steuerrecht - Gesellschaftsrecht - Rechtsvergleich - Rechtspolitik. MPI
3, Springer, Heidelberg 2013, XX + 876 p.
Schön, Wolfgang. Verabschiedung und Einführung – Max-Planck-Institut für ausländisches öffentliches Recht und Völkerrecht,
Heidelberg, 27. November 2013. ZaöRV
74/2014, No. 2, 177-184.
Schön, Wolfgang and Erik Röder (eds.).
Zukunftsfragen des deutschen Steuerrechts II. MPI Studies in Tax Law and Public
Finance, Volume 4, Springer Verlag, Heidelberg 2014, IX + 148 p.
Schön, Wolfgang. International Taxation
of Risk. Bulletin for International Taxation
68/2014, No. 6-7, 280-294 and Working
Paper of the Max Planck Institute for Tax
Law and Public Finance No. 2014-03 (http://
ssrn.com/abstract=2402612).
Schön, Wolfgang. Verdeckte Einlagen in
Kapitalgesellschaften - unsichtbar für den
EuGH?. Editorial, ZHR 178/2014, No. 4, 373386.
Schön, Wolfgang. Die Finanztransaktionssteuer – ein „fairer Beitrag“ des Finanzsektors?. Editorial, ZHR 176/2012, No. 3,
261-267.
Schön, Wolfgang. Zur Zukunft des Internationalen Steuerrechts. StuW 89[42]/2012,
No. 3, 213-224.
Published also in:
Praxis und Zukunft des deutschen Internationalen Steuerrechts, (ed.) J. Lüdicke, Dr.
Otto Schmidt, Cologne 2012, 1-28.
Schön, Wolfgang. The Distinct Equity of the
Debt-Equity Distinction. Bulletin for International Taxation 66/2012, No. 9, 490-502 and
Schön, Wolfgang. Deutsche Hinzurechnungsbesteuerung und Europäische Grundfreiheiten. IStR 22/2013, No. 6 (insert), 1-24.
Schön, Wolfgang. Das System der gesellschaftsrechtlichen Niederlassungsfreiheit
nach VALE. ZGR 42/2013, No. 3, 333-365.
Ault, Hugh, Wolfgang Schön, and Stephen
E. Shay. Base Erosion and Profit Shifting: A
Roadmap for Reform. Bulletin for International Taxations 68/2014, No. 6-7, 275-279.
Law - A Comparative Policy Analysis. British
Tax Review (BTR) 59/2014, No. 2, 146-217
79
79
Schön, Wolfgang. Transfer Pricing - Business Incentives, International Taxation
and Corporate Law. In: Fundamentals of
International Transfer Pricing in Law and
Economics, (eds.) W. Schön and K. Konrad,
MPI Studies in Tax Law and Public Finance,
Vol. 1, Springer, Heidelberg 2012, 47-67.
Schön, Wolfgang. State Aid in the Area of
Taxation. In: EU State Aids, (eds.) L. Hancher,
T. Ottervanger, and P. J. Slot, 4th Edition,
Sweet & Maxwell, London 2012, 321-362.
Schön, Wolfgang. The Permanent Establishment - One Word, Two Concepts. In: Festschrift in Honor of Professor Tadashi Murai,
(eds.) K. Kameda, Y. Kawabata, T. Miyamoto,
S. Nakamura, H. Urahigashi, and M. Tsuji,
Seibunsha Co., Osaka, Japan 2012, 437-442.
Schön, Wolfgang. Der Anspruch auf
Haftungsbschränkung im Europäischen
Gesellschaftsrecht. In: Festschrift für Peter
Hommelhoff zum 70. Geburtstag, (eds.)
B. Erle, W. Goette, D. Kleindiek, G. Krieger,
H.-J. Priester, C. Schubel, M. Schwab, C.
Teichmann, and C.-H. Witt, Dr. Otto Schmidt,
Cologne 2012, 1037-1057.
Schön, Wolfgang. Gläubigerschutz in der
geschlossenen Kapitalgesellschaft. In:
Rechtsregeln für die geschlossene Kapitalgesellschaft, (eds.) G. Bachmann, H. Eidenmüller, A. Engert, H. Fleischer, and W. Schön.
ZGR, Special Vol. 18, De Gruyter, Berlin 2012,
112-162.
English version:
Schön, Wolfgang. Creditor Protection in
the Closed Corporation (Chapter 5). In:
Regula-ting the Closed Corporation, (eds.)
G. Bachmann, H. Eidenmüller, A. Engert, H.
Fleischer, and W. Schön. ECFR Special Vol. 4,
De Gruyter, Berlin 2013, 124-178.
Schön, Wolfgang and Otmar Thömmes. Aktuelle Fragen zum Europäischen Steuer- und
Gesellschaftsrecht (1. Generalthema). In:
Jahrbuch der Fachanwälte für Steuerrecht
2012/2013, (eds.) K. Grundmann and K.-D.
Drüen, nwb, Herne 2012, 33-107.
Schön, Wolfgang. Grenzen der Rechtsdurchsetzung. In: Kollektiver Rechtsbruch - Gefahr
80
für unsere Freiheit, (ed.) C. Flick, Wallstein,
Göttingen 2013, 21-34.
English version:
The Limits of Law Enforcement. In: Collective Law-Breaking - A Threat to Liberty, (ed.)
C. Flick, Convoco Editions, Munich 2013,
27-42.
Schön, Wolfgang. Vorstandspflichten und
Steuerplanung. In: Festschrift für Michael
Hoffmann-Becking zum 70. Geburtstag,
(eds.) G. Krieger, M. Lutter, and K. Schmidt,
Verlag C.H. Beck, Munich 2013, 1085-1100.
Schön, Wolfgang. Internationales Steuerrecht (§ 150). In: Leitgedanken des Rechts
- Paul Kirchhof zum 70. Geburtstag, (eds.)
H. Kube, R. Mellinghoff, G. Morgenthaler,
U. Palm, T. Puhl, and C. Seiler, C.F. Müller,
Heidelberg 2013, 1625-1633.
Schön, Wolfgang. Transfer Pricing, the Arm’s
Length Standard and European Union Law.
In: Allocating Taxing Powers within the
European Union (MPI Studies in Tax Law
and Public Finance, Vol. 2), (eds.) W. Schön,
I. Richelle, and E. Traversa, Springer, Heidelberg 2013, 73-99.
Schön, Wolfgang. Eigenkapital und Fremdkapital - eine steuerpolitische Analyse. In:
2013/2014, (ed.) K.-D. Drüen, nwb, Herne
2013, 1-100.
Schön, Wolfgang. Die Funktion des
Unternehmenssteuerrechts im Einkommensteuerrecht. In: Erneuerung des Steuerrechts (DStJG Band 37), (ed.) M. Jachmann,
Dr. Otto Schmidt, Köln 2014, 217-258.
Schön, Wolfgang. Taxing Multinationals in
Europe. In: Høyt Skattet - Festskrift til Frederik Zimmer, (eds.) B. Banoun, O. GjemsOnstad, A. Aage Skaar, Universitetsforlaget,
Oslo 2014, 471-499.
2014/2015, (ed.) K.-D. Drüen, nbw, Herne
2014, 1-74.
Press Articles
Das große internationale Steuer-Spiel.
In: FAZ, No. 85, 12.04.13, p. 12.
Lob der Promotion. In: FAZ, No. 165,
19.07.2013, p. 9.
Ist Steuerwettbewerb illegal?. In: FAZ, No.
276, 27.11.14, p. 20.
Interviews
Staaten brauchen eine solide Besteuerungsgrundlage, Deutschlandradio Kultur,
22.04.2013
Wollen wir in systematischer Schönheit
sterben?. Gespräch zur steuerlichen Förderung von F&E. In: EY TAX & LAW 01/2014
Leichter auf die Anklagebank. Gespräch zur
aktuellen BEPS-Debatte. In: EY TAX & LAW
02/2014
Steueroasen in Europa. Gespräch mit Gabi
Kautzmann in der Sendung “orange”, Bayern
2, 21.06.2014.
Steuern - Demokratie hat ihren Preis. Sendereihe “Durchgecheckt”, ARTE, 23.09.2014.
Discussion Papers
Schön, Wolfgang. Taxing Multinationals
in Europe. Working Paper of the Max
abstract=2185282).
Forthcoming
Schön, Wolfgang. Beraterhaftung und hypothetischer Inzidentprozess. In: Rechtslage
- Rechtserkenntnis - Rechtsdurchsetzung
- Festschrifft für Eberhard Schilken zum
70. Geburtstag, (eds.) C. Meller-Hannich,
L. Haertlein, H.F. Gaul, E. Becker-Eberhard,
Verlag C.H. Beck, München 2015, 119-138.
Schön, Wolfgang. Kapitalverkehrsfreiheit
und Niederlassungsfreiheit. In: Privat- und
Wirtschaftsrecht in Europa - Festschrift für
Wulf-Henning Roth zum 70. Geburtstag,
(eds.) T. Ackermann, J. Köndgen, Verlag C.H.
Beck, München 2015, 553-583.
Mirna S. Screpante
Screpante, Mirna. Cross-Border Software
Transactions from a Technology Importing
Country Perspective: The Case of the Argentina-Germany Income and Capital Tax Treaty
(1978). Bulletin for International Taxation
67/2013, No. 9, 460-465.
Christian Sternberg
van Kesteren, Herman, Madeleine Merkx,
and Christian Sternberg. Dutch/German
Cross-Border VAT Grouping. EC Tax Review
22/2013, No. 4, 187-196.
Over-the-Counter Derivative Markets in the
Light of the EMIR Clearing Obligations and
the Financial Transaction Tax. Derivatives
and Financial Instruments (DFI) 8/2014, No.
2, 107-116.
German version:
EMIR-Clearing Pflicht und die Finanztransaktionssteuer. RdF 4/2014, No. 3, 211-220.
Legal Interpretation of Tax Law in Germany. In: Legal Interpretation of Tax Law (Series
on International Taxation; 46), (eds) R.
van Brederode and R. Krever, Kluwer Law
International, Alphen aan den Rijn 2014,
163-189.
81
81
Discussion Papers
Franan Vaquer Ferrer
Forthcoming
Sternberg, Christian. Die Umsatzbesteuerung gemeinnütziger Organisationen im
Binnenmarkt – Steuerbarkeit und Leistungsort, IFSt Schriftenreihe, forthcoming.
Sternberg, Christian. Steuerrechtsentwicklung in der BRD. In: Lexikon des Rechts,
Cologne, Wolters Kluwer, Gr. 6/1390, forthcoming.
Sternberg, Christian. Steuerreformen. In:
Lexikon des Rechts, Cologne, Wolters Kluwer, Gr. 6/1410, forthcoming.
Martina Sunde
Sunde, Martina. Entfalten die Grundfreiheiten ihre steuerlichen Auswirkungen auch
im Verhältnis zur Schweiz? Besprechung des
EuGH-Urteils vom 28.02.2013, C-425/11,
Ettwein. IStR 22/2013, No. 15, 568-573.
Lehner, Martin, Martina Sunde, and Patrick
Geißler. D-A-CH Steuer-Kongress 2013:
Probleme aus der aktuellen DBA-Praxis. IStR
22/2013, No. 17, 641-649.
Jieyin Tang
Tang, Jieyin. Legislative Choice on Tax for
Development of Financial Market with the
Focus on Function of Tax to Regulate. Taxation and Economy 2012, No. 2, 69-79.
Tang, Jieyin. Tax Treatment of Securitization of Credit Assets. Derivatives, Financial
Instruments 14/2012, No. 1, 1-6.
82
Vaquer Ferrer, Franan. Nuevo CDI entre
España y Alemania. La eliminación de la
cláusula de residencia ficticia del artículo 4.4
en materia de sociedades de personas: ¿Supresión de una cláusula conflictiva?. Civitas
Revista Española de Derecho Financiero
156/2012, No. 1, 131-151.
Alberto Vega
Discussion Papers
Vego, Alberto. International Governance
through Soft Law: The Case of the OECD
Transfer Pricing Guidelines. TransState
Working Paper No. 163, 2012 and Working
Vego, Alberto. Eurostat, Soft Law and the
Measurement of Public Debt: The Case of
Public-Private Partnerships. Working Paper
Wei Xiong
Evans, Chris and Wei Xiong. Towards an Improved Design of the Chinese General AntiAvoidance Rule: A Comparative Analysis.
Bulletin for International Taxation 68/2014,
No. 12, 686-696.
Max Planck Institute for Tax Law & Public Finance
Studies in Tax Law and Public Finance
Wolfgang Schön and Kai A. Konrad
Fundamentals of International Transfer
Pricing in Law and Economics
Band 1, Springer
Heidelberg 2012
Wolfgang Schön, Isabelle Richelle, and
Edoardo Traversa
Allocating Taxing Powers within the
European Union
Band 2, Springer
Heidelberg 2013
Wolfgang Schön
Eigenkapital und Fremdkapital: Steuerrecht
– Gesellschaftsrecht – Rechtsvergleich –
Rechtspolitik
Band 3, Springer
Heidelberg 2013
Wolfgang Schön and Erik Röder
Zukunftsfragen des deutschen Steuerrechts II
Band 4, Springer
Heidelberg 2014
83
83
Max Planck Institute for Tax Law & Public Finance
Research Paper Series
2012
2014
Boer, Martin J: A Few Comments on the
CCTB-Directive. Working Paper February
2012 (http://ssrn.com/abstract=2012276).
Schön, Wolfgang: International Taxation of Risk. Working Paper of the Max
abstract=2402612).
Röder, Erik: Proposal for an Enhanced CCTB
as Alternative to a CCCTB with Formulary
Apportionment. Working Paper of the Max
abstract=2012640).
Hellgardt, Alexander: Comparing Apples
and Oranges? Public, Private, Tax, and Criminal Law in Financial Markets Regulation.
Vega, Alberto: International Governance
through Soft Law: The Case of the OECD
Transfer Pricing Guidelines. TransState
Working Paper No. 163, 2012, and Working
Heber, Caroline and Christian Sternberg:
Schön, Wolfgang: The Distinct Equity of the
Debt-Equity Distinction. Working Paper of
Mostacatto, Bianca: Eliminating Regulatory
Reliance on Credit Ratings: Restoring the
Strength of Reputational Concerns. Working
Schön, Wolfgang, et.al.: Debt and Equity
in Domestic and International Tax Law – A
Comparative Policy Analysis. Working Paper
Public Finance 2014-09 (http://ssrn.com/
abstract=2444683).
Schön, Wolfgang: Taxing Multinationals
in Europe. Working Paper of the Max
abstract=2185282).
Röder, Erik: Co-ordination of Corporate Exit
Taxation in the Internal Market and Beyond. Working Paper of the Max Planck Institute
2013
Ault, Hugh: Some Reflections on the OECD
and the Sources of International Tax Principles. Working Paper of the Max Planck
Institute for Tax Law and Public Finance No.
2013-03 (ssrn.com/abstract=2287834).
84
Vega, Alberto: Eurostat, Soft Law and the
Measurement of Public Debt: The Case of
Public-Private Partnerships. Working Paper
II Lectures at Conferences or
Seminars
Hugh Ault
“Some Reflections on the OECD and the
Sources of International Tax Principles, 70
Tax Notes International”, MPI for Tax Law
and Public Finance, Munich, May 2013.
“The OECD and its BEPS Project: Where are
we and Where are we Going?”, Lecture, IFA Regional Meeting, Heidelberg, April 2013. Chiara Balbinot
“Systems of Differing Taxation of Legal
Forms under the Scrutiny of European State
Aid Law”, Poster Presentation, Scientific
Advisory Board Meeting, MPI for Tax Law
and Public Finance, Munich, July 2012.
“Beihilferecht und Rechtsformneutralität”,
Staff Retreat, Department of Business and
Tax Law, MPI for Tax Law and Public Finance,
Munich, February 2013.
“Beilhilfeverbot vs. Unternehmenssanierung? – Diskussion anhand von Sanierungsklausel und Sanierungserlass”,
Round Table of the MPI for Tax Law and
Public Finance, Munich, May 2013.
Comment on: Tim Stolper, “The Role of
Customer Coordination in the Fight Against
Tax Havens”, IV. Staff Retreat, MPI for Tax
Law and Public Finance, Kreuth, September
2013.
Comment on: Kasper Dziurdz, “Non‐Discrimination in International Tax Law”, 2nd
Max Planck European Postdoctoral Conference on Tax Law, MPl for Tax Law and Public
Finance, Munich, November 2013.
Ewa Bienkowska
“Tax Incentives for Technology Transfer to
LDCs”, Staff Retreat, Department of Business
and Tax Law, MPI for Tax Law and Public
Finance, Munich, February 2013.
Andreas Eggert
“The Computation of the Tax Base According to the CCCTB Proposal”, Poster Presentation, Scientific Advisory Board Meeting, MPI
for Tax Law and Public Finance, Munich, July
2012.
“Auslegung der Gewinnermittlungsregeln
der CCCTB”, Lecture, PAKT Project, Centre
for European Economic Research (ZEW),
Mannheim, February 2013.
“EU: Proposed Directive for a Common
Consolidated Corporate Tax Base (CCCTB)”,
Lecture, YIN Seminar, 68th Congress of the
International Fiscal Association, Mumbai,
India, October 2014.
Mauritz von Einem
“IP Migration – Tax Planning and Tax Policy”,
Presentation, Scientific Advisory Board
Meeting, MPI for Tax Law and Public Finance, Munich, July 2012.
“IP-Migration – Steuergestaltung mit Immateriellen Wirtschaftsgütern”, Research Seminar, Centre for European Economic Research
(ZEW), Mannheim, April 2013.
Kilian Eßwein
“Privatautonome Gestaltung der Vorstandshaftung”, Workshop Privatrecht, LudwigMaximilians-Universität München, Munich,
November 2012.
Deborah Fries
“Die steuerrechtliche Geschäftsführerhaftung in der Krise und Insolvenz: Ein Fiskusprivileg im Rechtsvergleich”, DoktorandenWorkshop Restrukturierung und Insolvenz
2014, Institut für Interdisziplinäre Restrukturierung e.V., Berlin, September 2014.
Eivind Furuseth
“The Relationship between Domestic AntiAvoidance-Rules and Tax Treaties”, The
85
85
Nordic Tax Conference, Stockholm, Sweden,
November 2012.
liger Verfügungen”, Aktuelle Stunde, MPI for
Comparative and International Private Law,
Hamburg, May 2014.
Birke Häcker
“Divergence and Convergence in the Common Law – Lessons from the Ius Commune”,
Obligations VII Conference, University of
Hong Kong, Hong Kong, July 2014.
“Die geplante EU-Verordnung zur genzüberschreitenden vorläufigen Kontopfändung
– Eine kritische Analyse”, Aktuelle Stunde,
MPI for Comparative and International Private Law, Hamburg, January 2012.
“Öffentlich-rechtliche Erstattungsansprüche
im deutsch-englischen Vergleich”, Workshop
Privatrecht, Ludwig-Maximilians-Universität
München, Munich, January 2012.
“The Case of All Souls College v.
Cod[d]rington (1720) – Litigation over the
Codrington Bequest”, Lunchtime Talk, All
Souls College, Oxford University, UK, February 2012.
“Direct and Indirect Enrichment at the
Claimant’s Expense in Three-Party Cases:
A Survey of the U.S. Restaement (Third) on
Restitution and Unjust Enrichment”, R3RUESymposium, Brasenose College, Oxford
University, UK, May 2012.
“Das englische Recht und die europäische
Rechtstradition”, Evening Lecture, Summer
Academy of the German Scholarship Foundation, San Giovanni in Valle Aurina, Alto
Adige, Italy, August 2013.
Comment on: Jens Dammann, “The Mandatory Law Puzzle: Redefining American
Exceptionalism in Corporate Law”,
3rd Annual Meeting of the Alumni Association of the MPI for Tax Law and Public
86
Caroline Heber
Comment on: Juan Benito Gallego López,
“OTC Derivatives and the European Financial
Transaction Tax – Open Issues”, 2nd Max
Planck European Postdoctoral Conference
on Tax Law, MPl for Tax Law and Public
“OTC Derivatives in the Light of EMIR Clearing Obligations and the FTT”, IBFD FTT Confence, Madrid, Spain, February 2014.
“Enhanced Cooperation Procedure and Tax
Law”, IBFD Postdoctoral International Tax
Forum (PITF), Amsterdam, Netherlands,
May 2014.
“Umsatzsteuerrechtliche Behandlung von
Forschungskooperationen”, Discussion
Round, Federal Ministry of Finance, Berlin, July 2014.
“European Financial Transaction Tax – Scope
and Interplay with European Market Regulation”, Research Seminar, Centre for European Economic Research (ZEW), Mannheim,
July 2014.
“Research Institutes in the Scope of VAT”,
European Commission, Brussels, Belgium,
September 2014.
“(Fall)Recht als System? Zum Umgang des
Common Law mit Systematisierungsfragen”,
4. Zukunftsfakultät – “Recht als System”,
Recht im Kontext: Rechtskulturen, Institute
for Advanced Study, Berlin, December 2013.
Comment on: Esperanza Buitrago, “Taxpayers Rights: Fresh Hopes or Old Concerns?”,
4th Annual Meeting of the Alumni Association of the MPI for Tax Law and Public
“Mistaken Gifts after Pitt v Holt”, Current
Legal Problems Lecture, University College,
London, UK, February 2014.
“Mehrwertsteuerrechtliche Behandlung von
Forschungskooperationen”, Freiburger
Arbeitstagung, Freiburg, November 2014.
“Das vertauschte Testament. Oder: Über die
Form, Auslegung und Berichtigung letztwil-
“Verrechnungspreise und Konzernumlagen
in der Umsatzsteuer”, 2. Umsatzsteuerkonferenz, Munich, November 2014.
Alexander Hellgardt
“Der Ursprung des heutigen Privat
rechtsverständnisses in der romanistischen
Tradition des 19. Jahrhunderts”, Aktuelle
Stunde, MPI for Comparative and International Private Law, Hamburg, January 2012.
“Bankenregulierung mittels Steuern und
Abgaben”, Team Hopt, MPI for Comparative
and International Private Law, Hamburg,
January 2012.
“The Bank Levy as an Example of a Corrective Tax”, Seminar: Taxation of the Financial
Sector, MPI for Tax Law and Public Finance,
Munich, February 2012.
“Comparing Apples and Oranges? Public,
Private, and Criminal Law in Financial Markets Regulation, Conference”, Legal Challenges Arising out of the Global Financial
Crisis: The Euro, Bail-outs, and Regulation,
The Queen’s College, Oxford, UK, March
2012.
“Anforderungen an die Wahl von Regelungsinstrumenten aufgrund des ver
fassungsrechtlichen Erforderlichkeitsgebots”, Habilitandentreffen, Mannheim, June
2012.
“Comparing Apples and Oranges? Different
Legal Instruments in Financial Markets Regulation”, Presentation, Scientific Advisory
Board Meeting, MPI for Tax Law and Public
Finance, Munich, July 2012.
“EU-Regeln zur Kapitalmarktinformations
haftung”, DAI-Seminar, Organhaftung mit
Auslandsbezug, Frankfurt, October 2012.
“Regulierung als Funktion des Rechts”,
Habilitandentreffen, Frankfurt, December
2012.
“Regulierung mittels Privatrecht”, Habilitandenkolloquium, MPI for Comparative and
International Private Law, Hamburg, April
2013.
“Die Regulierungsfunktion des Sachenrechts”, Habilitandentreffen, Hamburg, June
2013.
Comment on: Philipp Meyer-Brauns, “Financial Contracting with Tax Evaders”, IV. Staff
Retreat, MPI for Tax Law and Public Finance,
Kreuth, September 2013.
Comment on: Jennifer Hill, “Visions of the
Shareholder in the Post-Crisis Era”, MunichSydney-Conference on the Law and Economics of Taxation, MPI for Tax Law and Public
Finance and University of Sydney, Munich,
September 2013.
“Parallelwelten der allgemeinen Rechtsgeschäftslehre – Privatautonome Alternativen
zu den §§ 116 ff., 145 ff. BGB”, Workshop
Privatrecht, Faculty of Law, LudwigMaximilians-Universität München, Munich,
December 2013.
“Parallelwelten der allgemeinen Rechtsgeschäftslehre”, Habilitandentreffen, Frankfurt, January 2014.
“Staatsrechtliche Zulässigkeit der Regulierung mittels Privatrecht”, Habilitandentreffen, Munich, June 2014.
Yasmin Holm
“International Profit Attribution: Implementation of the AOA into German Law”, IfA
Poster Programme at the 67th Annual Congress, Copenhagen, Denmark, August 2013.
“Gewinnermittlung bei Betriebsstätten”,
IV. Staff Retreat, MPI for Tax Law and Public
Finance, Kreuth, September 2013.
“Der AOA in seiner Umsetzung in deutsches
Recht. Betriebsstättenbesteuerung unter
Anwendung von § 1 AStG”, Poster Programme, 38. Jahrestagung der Deutschen
Steuerjuristischen Gesellschaft (DStJG),
Berlin, September 2013. Šime Jozipović
“The Applicability of the Strategic Investment
Act on Energy Law Regulations”, Symposium:
Energy– and Environmental Law with Focus
on Renewable Energy – Freie Universität
Berlin, University of Split, Split, Croatia, May
2013.
87
87
“The Legal Borders of Croatian Industrial
Policy in the Field of Taxation and Technological” (together with A. Nanić and A.
Jukić), Advancement – International Conference on the Role of Europe’s Industry in the
21st Century – The Institute of Economics
Zagreb (EIZ), Zagreb, Croatia, November
2013.
“Fines and Civil Mechanisms of Redress
Against Cartels in the Energy Sector”,
International Symposium: Energy- and
Environmental Law With Special Focus on
Renewable Energy, Freie Universität Berlin,
University of Split, Split, Croatia, May 2014.
Leif Klinkert
“Problems of Statutory Constraints on Dividend Distributions with a Focus on
§ 268(8) HGB”, Poster Presentation, Scientific Advisory Board Meeting, MPI for Tax
Law and Public Finance, Munich, July 2012.
Sarah Lindeberg
Comment on: Harm van den Broek, “Combating Hybrid Mismatches”, 2nd Max Planck
European Postdoctoral Conference on Tax
Law, MPl for Tax Law and Public Finance,
Munich, November 2013.
Angelika Meindl
“Comparison of the BVerfG’s and the ECHR’s
Jurisprudence”, Poster Presentation, Scientific Advisory Board Meeting, MPI for Tax
Law and Public Finance, Munich, July 2012.
“Beneficial Ownership in den USA”, Meeting
of the Board of Trustees, MPI for Tax Law
Toshiko Miyamoto
“A Study on International Inheritance Tax in
the EU”, Joint Seminar of Kansai University
Tax Law Society, Ritsumeikan University
Tax Law, and Public Finance Society, Kyoto,
Japan, May 2014.
88
“Cross-border Reorganization and Exit Tax in
the EU”, Joint Seminar of Kansai University
Tax Law Society, Ritsumeikan University
Tax Law, and Public Finance Society, Kyoto,
Japan, October 2014.
Bianca Mostacatto
“Managers’ Duties with Regard to Tax Planning: a Comparative Analysis”, Poster Presentation, Scientific Advisory Board Meeting,
MPI for Tax Law and Public Finance, Munich,
July 2012.
“International Taxation of Income from
Enterprise Services: Attribution of Tax
Competence under the OECD-, UN- and USModel DTCs”, Poster Presentation, Scientific
“International Taxation of Income from Services under Double Taxation Conventions”,
January 2013.
“International Taxation of Income from
Enterprise Services under Double Taxation
Conventions”, Poster Presentation at the
“EATLP Doctorate Seminar on European Tax
Law”, Vienna, Austria, February 2013.
“Taxation of Cross-border Services”, IV. Staff
Retreat, MPI for Tax Law and Public Finance,
Kreuth, September 2013.
“German Tax Law in Light of the Constitution & BrazilianTax Law in Light of the Constitution”, Lecture at the Heidelberg University – Fourth Colloquium on Aspects of the
Portuguese-Speaking World: German- and
Portuguese-Speaking Legal Traditions and
Legal Terminology, Heidelberg, June 2014.
“German Tax Law in Light of the Constitution & Brazilian Tax Law in Light of the
Constitution”, Lecture at the Law Faculty of
the University of São Paulo (via webinar),
Munich-São Paulo (webinar), November
2014.
“Ermittlung des Nachlasses: Informationsansprüche im Erbrecht”, 7. Deutscher
Erbrechtstag, Berlin, March 2012.
“Gestaltungsfreiheit im Steuerrecht”, Habilitandenkolloquium, MPI for Comparative
and International Private Law, Hamburg,
April 2013.
Comment on: Patricia F. Apps and Ray
Rees, “Optimal Taxation of Capital Income”,
Economics of Taxation, MPI for Tax Law and
Public Finance and University of Sydney,
Munich, September 2013.
“Gestaltungsmissbrauch im Steuerrecht”,
“Die Besteuerung von Personengesellschaften”, Panel Discussion, Deutsches
Anwaltsinstitut e.V., Munich, October 2013.
Comment on: Hanna Filipczyk, “Is Tax
Avoidance (Im)Moral? Ethics, Metaethics
and Taxes”, 2nd Max Planck European Postdoctoral Conference on Tax Law, MPl for Tax
Law and Public Finance, Munich, November
2013.
“Gefangen in der Vor- und Nacherbschaft?”,
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, July 2014.
Susanne Risch
“Die Genfer Wertpapierkonvention”,
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, May 2013.
Erik Röder
“Towards a Common Corporate Tax Base”,
Presentation, Scientific Advisory Board
Meeting, MPI for Tax Law and Public Finance, Munich, July 2012.
“Die Kommanditgesellschaft im Rechtsvergleich: Hintergründe für die unterschiedliche Karriere einer Rechtsform”, Workshop
Privatrecht, Ludwig-Maximilians-Universität
München, Munich, October 2012.
“Das Konzept einer CCTBplus: Ein Vorschlag
zur Nutzung des vollen Potentials einer harmonisierten Bemessungsgrundlage”,
CCCTB – neues Leitbild für die Unternehmensbesteuerung in Europa?, 16. Vortrags- und Diskussionsveranstaltung der
Düsseldorfer Vereinigung für Steuerrecht,
Heinrich-Heine-Universität, Düsseldorf,
January 2013.
“Perspectives of Corporate Tax Harmonisation in Europe” (together with Prof. Dr. C.
Spengel), PAKT Policy Conference, Landesvertretung Baden-Württemberg bei der EUKommission, Brussels, Belgium, April 2013.
Comment on: Celeste M. Black, “Accounting for Carbon Emission Allowances in the
European Union: In Search of Consistency”,
Public Finance, Munich, September 2013.
Comment on: Maximilian Haag, “Typische
Probleme der Unternehmensnachfolge:
Mitunternehmerschaft und Nießbrauch im
Lichte von Einkommensteuer und Erbschaftsteuer“, 3rd Annual Meeting of the Alumni
Association of the Max Planck Institute for
Tax Law and Public Finance, Munich, November 2013.
Comment on: Frederik Boulogne, “Shortcomings in the Merger Directive”, 2nd Max
Planck European Postdoctoral Conference
on Tax Law, MPI for Tax Law and Public
“German Cases: C-560/13 (Wagner-Raith)
and C-559/13 (Grünewald)”, Recent and
Pending Cases at the ECJ on Direct Taxation,
Vienna University of Economics and Business, Vienna, Austria, November 2013.
“Vom Sinn und Unsinn des Nutzungsausgleichs bei der Rückabwicklung von Verträgen”, Staff Retreat, Department of Business
and Tax Law, MPI for Tax Law and Public
Finance, Munich, February 2014.
89
89
“Reformüberlegungen zum Recht der GbR”,
Workshop Privatrecht, Juristische Fakultät
der Ludwig-Maximilians-Universität, LudwigMaximilians-Universität, Munich, July 2014.
“Entstrickungsbesteuerung im Binnenmarkt
– Notwendigkeit und Ausgestaltung einer
Harmonisierung”, Meeting of the Board
of Trustees, MPI for Tax Law and Public
“Die vorzeitige Beendigung von Darlehensverträgen gegen Vorfälligkeitsentschädigung
im Spannungsfeld von Rechtsfortbildung
und Kodifizierung”, „Richterliche Rechtsfortbildung und kodifiziertes Richterrecht“
– 25. Tagung der Gesellschaft junger Zivilrechtswissenschaftler, Universität zu Köln,
Cologne, September 2014.
“German LP and US LLC: Insights into the
Evolution of two Equivalent Business Entities”, Faculty Talk, University of Florida,
Levin College of Law, Gainesville, USA,
November 2014.
“Harmonisation of Corporate Exit Taxation:
Need and Perspectives”, Research Seminar
Series – Michaelmas Term 2014, Oxford
University Centre for Business Taxation,
Oxford, UK, November 2014.
Wolfgang Schön
“Materielle Gestaltungsschwerpunkte
– Personen- und Kapitalgesellschaften”,
Panel Chair, Fachinstitut für Steuerrecht,
Deutsches Anwaltsinstitut e.V., Munich,
January 2012.
“Reformoptionen bei der Einkommen
steuer”, CDU/CSU-Fraktion, Klausursitzung,
Bayerische Landesvertretung Berlin, Berlin,
February 2012.
“Corporate Governance und Steuern”, Dahlem Lectures on FACTS, Corporate Governance: aktuelle Probleme, Freie Universität
Berlin, Berlin, February 2012.
“Perspektiven der Unternehmensbesteuerung”, Haarmann Steuerkonferenz 2012,
Berlin, March 2012.
90
“Aktuelle Fragen zum Europäischen Steuerund Gesellschaftsrecht”, 63. Steuerrechtliche Jahresarbeitstagung Unternehmen
2012, 1. Generalthema, Arbeitsgemeinschaft der Fachanwälte für Steuerrecht e.V.,
Wiesbaden, May 2012.
“Euro- und Staatsschuldenkrise als He
rausforderung an die nationale und europäische Steuerpolitik”, Weichenstellung
der deutschen und europäischen Steuerpolitik, IFSt-Jahrestagung 2012, Haus der
deutschen Wirtschaft, Berlin, June 2012.
“Transfer Pricing and Integration Benefits”,
Intangibles and Transfer Pricing, MPI for Tax
Law and Public Finance, INTR, Deutsche IFA,
Munich, July 2012.
“Grenzen der Durchsetzbarkeit des Rechts”,
Convoco Forum 2012, Zwischen Sein und
Sollen – Kollektiver Rechtsbruch als Gefahr
für unsere Freiheit, Universität Salzburg,
Mozarteum, Salzburg, Austria, July 2012.
“Taxing Multinationals in Europe”, Seminar
on International Tax Reform, Harvard Law
School, Woodstock, USA, August 2012.
“Taxing Multinationals in Europe”, MunichTokyo-Conference on Federal Public
Economics, Social Science Research Center
Berlin (WZB), MPI for Tax Law and Public
Finance, Munich, September 2012.
“International Allocation of the Corporate
Tax Base”, Conference in Honor of Hugh
Ault, Boston, USA, September 2012.
“From Global Networks to Global
Science?”, Network of Trust: Will the New
Social Media Change Global Science?, Panel
Discussion, 6th Forum on the Internationalization of Sciences and Humanities, Alexander von Humboldt Foundation, Berlin,
October 2012.
“Materielle Gestaltungsschwerpunkte
– Personen- und Kapitalgesellschaften”,
Panel Chair, Fachinstitut für Steuerrecht,
Deutsches Anwaltsinstitut e.V., Munich,
January 2013.
“Taxing Multinationals in Europe”, Faculty
of Law, University of Oxford, Oxford, UK,
March 2013.
“Transfer Pricing and Integration Benefits”,
Saïd Business School, Centre for Business
Taxation, University of Oxford, Oxford, UK,
March 2013.
“Returns, Risks and Rents: How to Tax
International Business Income”, Taxing
Multinationals: The International Allocation
of the Tax Base, Max Planck Institute for Tax
Law and Public Finance, Centre for Business
Taxation, Oxford University, Oxford, UK,
March 2013.
“Die deutsche Verhandlungsgrundlage für
Doppelbesteuerungsabkommen”, Panel Discussion, Federal Ministry of Finance, Berlin,
April 2013.
“Das große internationale Steuer-Spiel”,
Thinkers’ Corner, Hochschule für Philosophie, Munich, May 2013.
“Aktuelle Fragen zum Europäischen Steuerund Gesellschaftsrecht”, 64. Steuerrechtliche Jahresarbeitstagung Unternehmen
2013, 1. Generalthema, Arbeitsgemeinschaft der Fachanwälte für Steuerrecht e.V.,
Wiesbaden, May 2013.
“Welcoming Address”, Opening Ceremony
Max Planck Institute Luxembourg for International, European and Regulatory Procedural Law, Luxembourg, May 2013.
“Basics for BEPS: How to Tax International
Business Income”, ATOZ Chair for European
and International Taxation, University of
Luxembourg, Luxembourg, May 2013.
“Leitideen des Steuerrechts, Leitgedanken
des Rechts”, Symposium anlässlich des 70.
Geburtstages von Paul Kirchhof, Alte Universität, Heidelberg, June 2013.
“International Competitiveness of Tax
Systems”, International Tax Conference:
Protecting the Tax Base, Confederation of
Swedish Enterprise, Stockholm, Sweden,
June 2013.
rung des Steuerrechts, 38th Annual Meeting
of the Deutsche Steuerjuristische Gesellschaft e.V., Humboldt Universität zu Berlin,
Berlin, September 2013.
“International Taxation of Risk”, MunichSydney-Conference on the Law and Economics of Taxation, MPI for Tax Law and Public
September 2013.
“Risk and Taxation – the Legal View”,
“Von der Rechtsdogmatik zur Rechtsökonomie: Laudatio auf Gerhard Wagner”, Laudatio anlässlich der Verleihung des Preises
der Berlin-Brandenburgischen Akademie
der Wissenschaften (gestiftet von der Commerzbank-Stiftung) an Professor Gerhard
Wagner, Berlin, November 2013.
“Steuerpolitik 2013: Ein Steuerrecht für die
Wissensgesellschaft”, 49. Berliner Steuergespräch, Steuerpolitische Perspektiven der
neuen Legislaturperiode, Berlin, November
2013.
“Grenzüberschreitungen im Steuerrecht,
Steuerrechtswissenschaft: Disziplinierung
– Grundfragen – Koordinaten”, Workshop,
Schloss Mickeln, Düsseldorf, November
2013.
Verabschiedung und Einführung anlässlich
des “Stabwechsels”, MPI for Comparative
Public Law and International Law, Heidelberg, November 2013.
“Tribute, `The Anthropocene´ Symposium”,
80th Birthday of Paul Crutzen, Mainz, December 2013.
“International Taxation of Risk (Shifting)”,
Base Erosion and Profit Shifting: A Roadmap
for Reform, MPI for Tax Law and Public
Finance, INTR, Munich, January 2014.
“The Increasing Pressure to Implement
Tax Strategy and Tax Risk Management”,
Panelist, 3rd Annual WTS International Tax
Conference, Munich, January 2014.
“Die Funktion des Unternehmenssteuerrechts im Einkommensteuerrecht”, Erneue-
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“Die Zukunft des Unternehmens- und Internationalen Steuerrechts”, Haarmann Steuerkonferenz 2014, Berlin, February 2014.
“Welcome Address”, Opening Ceremony,
Population Europe Exhibition, Berlin, April
2014.
“Recent Cases of the German Constitutional
Court in Matters of Taxation”, Peking University, Beijing, China, May 2014.
“International Competition and German Tax
Policy”, Summer Conference 2014: Tax Competition and BEPS, Saïd Business School,
Oxford University Centre for Business Taxation, Oxford, UK, June 2014.
“Introduction”, Convoco Forum, Unterlassen
– Die anspruchsvollste Form des Handelns?
Ein Plädoyer für Mass und Ziel, Mozarteum,
Salzburg, Austria, July 2014.
“International Taxation of Risk”, Davis Polk
& Wardwell Columbia Law School Tax Policy
Colloquium, Columbia Law School, New
York, USA, September 2014.
“International Taxation of Risk”, The James
Hausman Tax Law and Policy Workshop
Series, University of Toronto, Faculty of Law,
Toronto, Canada, October 2014.
“Neutrality and Territoriality – Competing or
Converging Concepts in European Tax Law?”,
Klaus-Vogel-Lecture, Wirtschaftsuniversität
Wien, Austria, Vienna, October 2014.
“Eröffnung, Moderation, Podiumsdiskussion”, 14. IStR-Jahrestagung 2014, Berlin,
November 2014.
“Wissenschaftliche Einführung”, International
Tax Audit Forum München – Grenzüberschreitende Betriebsprüfungen, ITAX Auslandsfachprüfertagung, Munich, November 2014.
“Die Auswirkungen von Base Erosion and
Profit Shifting (BEPS) auf Corporate Governance und Rechnungslegung”, 56. IDW Arbeitstagung, Baden-Baden, November 2014.
“Neutralität und Territorialität – Gegensätze
oder Grundsätze des Europäischen Steuerrechts?, MPI for Tax Law and Public Finance,
Munich, December 2014.
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Julian Schroeder
“Die Prospekthaftung des Emittenten und
seiner Vorstandsmitglieder nach den §§ 21
ff. WpPG und §§ 20 ff. VermAnlG, Stifterverband für die deutsche Wissenschaft”. Annual Conference of the Working Group for
Business and Law (Arbeitskreis Wirtschaft
und Recht), Munich, May 2014.
Mirna Solange Screpante
“The Taxation of Software between Argentina and Germany.” Staff Retreat, Department
of Business and Tax Law, MPI for Tax Law
and Public Finance, Munich, February 2013.
Amelie Singer
“Das Common European Sales Law im Lichte
des Internationalen Privatrechts”, Staff Retreat, Department of Business and Tax Law,
February 2013.
“Das Common European Sales Law im Lichte
des Internationalen Privatrechts”, Doktorandenseminar, Albert-Ludwigs-University of
Freiburg, Freiburg, April 2013.
Christian Sternberg
Comment on: Fangfang Tan, “Learning
Dynamics in Tax Evasion”, IV. Staff Retreat,
MPI for Tax Law and Public Finance, Kreuth,
September 2013.
“OTC Derivatives in the Light of EMIR Clearing Obligations and the FTT”, IBFD FTT Conference, Madrid, Spain, February 2014.
“Formelaufteilung nach der GKKB und Völkergewohnheitsrecht”, Staff Retreat, Department of Business and Tax Law, MPI for Tax
Law and Public Finance, Munich, February
2014.
“Formula Apportionment in the EU”, Doctoral Meeting for Students of International Tax
Law, Amsterdam, Netherlands, May 2014.
“European Financial Transaction Tax – Scope
and Interplay with European Market Regula-
tion”, Research Seminar, Centre for European
Economic Research (ZEW), Mannheim, July
2014.
Martina Sunde
“Die integrative Kraft der Assoziierungskompetenz – oder wie der EuGH mit Sonderrechten einzelner Mitgliedstaaten umgeht”,
PAKT-Workshop, Centre for European
Economic Research (ZEW), Mannheim, May
2014.
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III Editorial Services
IV Activities and Memberships
Wolfgang Schön
Series Co-editor: MPI Studies in Tax Law and
Public Finance.
Member, Gesellschaftsrechtliche
Vereinigung – Wissenschaftliche Vereinigung
für Unternehmens- und Gesellschaftsrecht
(VGR) e.V.
Series Co-editor: Rechtsordnung und
Steuerwesen.
Chiara Balbinot
Journals
Member, Deutsch-Italienische Juristenvereinigung e.V.
Book Series
Managing Editor: Zeitschrift für das gesamte
Handelsrecht und Wirtschaftsrecht.
Co-editor: Deutsche Steuer-Zeitung.
Member of the Editorial Advisory Panel:
Der Konzern.
Co-editor: Internationales Steuerrecht.
Co-editor: World Tax Journal.
Member of the Advisory Board: European
Business Organization Law Review.
Member of the Advisory Board: Dirito e
Practica Tributaria Internazionale.
Member of the Editorial Advisory Panel:
British Tax Review.
Networks
Co-editor: Social Science Research Network/
Max Planck Institute for Tax Law & Public
Finance Research Paper Series.
Birke Häcker
Fellow, All Souls College, University of
Oxford.
Fellow, European Law Institute, Brussels /
Vienna.
Member, Gesellschaft für Rechtsvergleichung e.V.
Member, Habilitand(inn)enzirkel,
Zukunftsfakultät, Recht im Kontext: Rechtskulturen, Wissenschaftskolleg zu Berlin.
Lehrbeauftragte, Faculty of Law, LudwigMaximilians-Universität München, Munich.
Mentee of the Ludwig-Maximilians-Universität München Excellence-Program.
Andreas Eggert
Member, International Fiscal Association
(IFA).
Member, Deutsche Steuerjuristische Gesellschaft (DStJG).
Member, Augsburger Forum für Steuerrecht.
Caroline Heber
(IFA).
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Member, Young IFA Network (YIN).
Bianca Mostacatto
Member, Australasian Tax Teacher Association (ATTA).
Member, Brazilian Lawyers’ Association
(Ordem dos Advogados do Brasil).
Alexander Hellgardt
Assistant Professor of Law, Faculty of Law,
Universidade Candido Mendes, Rio de
Janeiro, Brasil.
Elected Scientific Staff Employee to the
Human Sciences Section and the Scientific
Council of the Max Planck Society, until June
2014.
Member, Institute’s Committee, until June
2014.
Member, Board of the MPDL, until June
2014.
Member, German Lawyers’ Association
(Deutscher Juristentag).
Member, German-American Lawyers Association (Deutsch-Amerikanische Juristenvereinigung e.V.).
Member, Friends of the Hamburg Max
Planck Institute for Comparative and International Private Law (Freunde des Hamburger Max-Planck-Instituts für ausländisches
und internationales Privatrecht e.V.).
Member, ASA Below 40 (ASA – Association
Suisse d’Arbitrage).
Toshiko Miyamoto
(IFA).
Member of the Board, The Japanese Society
for Tax Law.
(IFA).
Member, German-Brazilian Law Association
(Deutsch-Brasilianische Juristenvereinigung).
Member, Gesellschaftsrechtliche Vereinigung – Wissenschaftliche Vereinigung für
Unternehmens- und Gesellschaftsrecht e.V.
(VGR).
Member, Gesellschaft Junger Zivilrechtswissenschaftler e.V. (GJZ).
Member, German Lawyers’ Association
(Deutscher Juristentag).
Fellow, European Law Institute.
Member, Gesellschaft junger Zivilrechtswissenschaftler e.V. (GJZ).
Member, Harvard Law School Association of
Germany e.V.
Lehrbeauftragter, Faculty of Law, LudwigMaximilians-Universität München, Munich.
Member, Arbeitsgemeinschaft Erbrecht des
DAV.
Yasmin Holm
Member, Gesellschaftsrechtliche Vereinigung – Wissenschaftliche Vereinigung für
Unternehmens- und Gesellschaftsrecht e.V.
(VGR).
Member, Institute’s Committee, since July
2014.
Lehrbeauftragte, Faculty of Law, LudwigMaximilians-Universität München, Munich.
Mentee of the Ludwig-Maximilians-Universität München Excellence-Program.
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Leopoldo Parada
Member, Chilean Bar Association.
Member, American Bar Association (ABA),
Section of Taxation, 2012-2014.
Member, German Law Professors’ Working
Group on Accounting Law, since 1996.
Member, 2015 IRS Directory of Tax Preparers with Professional Credentials and other
Selected Qualifications.
Working Group for Business and Law (Arbeitskreis “Wirtschaft und Recht” im Stifterverband für die deutsche Wissenschaft),
since 1997.
Erik Röder
Member, Board of Trustees, International
Bureau of Fiscal Documentation, since 2003.
2014.
Member, Board of Trustees, Berliner Steuergespräche e.V., since 2003.
Member, Permanent Scientific Committee,
International Fiscal Association, since 2005.
Member, Gesellschaft Junger Zivilrechtswissenschaftler e.V. (GJZ).
Member, Board of the International Fiscal
Association, German Branch, since 2005.
Lehrbeauftragter, Faculty of Law, LudwigMaximilians-Universität München, Munich.
Member, Research Board, Ludwig-Maximilians-Universität München, since 2006.
Wolfgang Schön
Member, Board of Trustees, Hertie School of
Governance, since 2008.
Research and Teaching Positions
Member, Senate of the Max Planck Society,
2008–2014.
Honorary Professor, Faculty of Law, LudwigMaximilians-Universität München, since
2002.
Member, Board of Trustees, Max Planck
Foundation, 2008–2014.
Vice President, Max Planck Society, Munich,
06/2008 – 06/2014.
Vice President, German Research Foundation (Deutsche Forschungsgemeinschaft),
Bonn, since 07/2014.
Fellowships and Honours
International Research Fellow, Oxford University Centre of Business Taxation, since
2006.
Member, Global Law Faculty, New York University, since 2009.
Professional Activities
Expert, Deutscher Bundestag, Committee of
Fiscal Affairs, since 1995.
96
Member, Scientific Committee, German Tax
Law Association, since 1995.
Vice Chair, Permanent Scientific Committee,
International Fiscal Association, 2008–2014.
Member, Board of Trustees, ifo-Institut für
Wirtschaftsforschung e.V., since 2009.
Member, Executive Board, Max Planck
Luxembourg Foundation, 2012–2014.
Member, Board of Trustees, Bayerische
Staatsbibliothek e.V., since 2013.
Member, Scientific Advisory Board, Leibniz
ScienceCampus MaTax, since 2014.
Member, Arbeitskreis “Verrechnungspreise”
der Schmalenbach Gesellschaft, since 2014.
Memberships in Scientific Associations
VTeaching
German Lawyers’ Association (Deutscher
Juristentag), since 1986.
German Association of Civil Law Teachers
(Zivilrechtslehrervereinigung), since 1992.
Tutorial on “Civil Law for Foreign Students”
(Zivilrecht für ausländische Studierende),
LL.M. Program, Law Faculty, LudwigMaximilians-Universität München, Munich,
Winter Term 2012/13.
Member, Deutsche Steuerjuristische Gesellschaft (DStJG), since 1995.
Hugh Ault
VAT Forum (Umsatzsteuer-Forum e.V.), since
1988.
German Association for Business and Company Law (Wissenschaftliche Vereinigung
für Unternehmens- und Gesellschaftsrecht),
since 1996.
Seminar on “OECD Treaty Negotiations
Process”, Heidelberg University (Prof E.
Reimer), 19-20 April 2013.
Fachinstitut der Steuerberater, since 1996.
Birke Häcker
European Association of Tax Law Professors
(EATLP), since 1999.
Lecture on “Einführung in das englische
Recht”, Ludwig-Maximilians-Universität
München, Munich, Winter Term 2011/12.
International Fiscal Association (IFA), since
2003.
Christian Sternberg
(IFA).
Member, Young IFA Network.
Member, Westfälischer Steuerkreis.
Lecture on “Einführung in das englische
Recht” Ludwig-Maximilians-Universität
München, Munich, Summer Term 2012.
“Den Reichen nehmen, den Armen geben:
Von Räubern, Banditen und Piraten in
‘sozialer Mission’”, Summer Academy of the
German Scholarship Foundation (together
with Prof. Dr. P. Wittig), San Giovanni in Valle
Aurina, Alto Adige, Italy, 18-31 August 2013.
Alexander Hellgardt
Corporate and Securities Law, Munich
University Summer Training in German and
European Law, Ludwig-Maximilians-Universität München, Munich, July 2012.
Arbeitsgemeinschaft zu “Grundkurs im
Zivilrecht I”, Ludwig-Maximilians-Universität
Rechtstheoretisches Kolloquium “Öffentliches Recht und Privatrecht“ (together
with Dr. S. Unger), Ludwig-MaximiliansUniversität München, Munich, Summer
Term 2013.
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Grundlagenseminar “Verfassungsgerichtsentscheidungen zum Privatrecht“
(together with Prof. Dr. Dr. h.c. W. Schön, Dr.
C. Osterloh-Konrad, Dr. E. Röder), LudwigMaximilians-Universität München, Munich,
Summer Term 2013.
Christine Komisarczyk
“Corporate and Securities Law”, Course for
the Munich University Summer Training
in German and European Law, LudwigMaximilians-Universität München, Munich,
July 2013.
Stefan Kreutzer
Rechtstheoretisches Kolloquium “Interdisziplinarität im Recht” (together with Dr. S.
Unger), Ludwig-Maximilians-Universität
“Introduction to English Law”, Lecture
Series, Ludwig-Maximilians-Universität
Rechtstheoretisches Kolloquium “Interdisziplinarität im Recht” (together with Dr. S.
Unger), Ludwig-Maximilians-Universität
Lecture “Europäisches und internationales
Unternehmensrecht” (together with Prof.
Dr. Schön), Ludwig-Maximilians-Universität
Corporate and Securities Law, Course for
the Munich University Summer Training
in German and European Law, LudwigMaximilians-Universität München, Munich,
July 2014.
Yasmin Holm
Arbeitsgemeinschaft zu “Grundkurs Öffentliches Recht II (Grundrechte)”, LudwigMaximilians-Universität München, Munich,
Summer Term 2013.
Arbeitsgemeinschaft zu “Grundkurs Öffentliches Recht I (Staatsorganisationsrecht)”,
Ludwig-Maximilians-Universität München,
Munich, Winter Term 2013/14.
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Examinatorium zum Steuerrecht, LudwigMaximilians-Universität München, Munich,
Summer Term 2012.
Arbeitsgemeinschaft zu “Grundkurs Zivilrecht I”, Ludwig-Maximilians-Universität
Sara Lindeberg
Lecture “Participation Exemption Regime”,
BI Norwegian Business School, Oslo, Norway, November 2013.
Fachsprachkurs “Brazilian Constitutional and
Tax Law and on Brazilian Legal Terminology”
(Linguagem e temas jurídicos brasileiros 4),
Munich, Summer Term 2012.
Fachsprachkurs “Brazilian Constitutional and
Tax Law and on Brazilian Legal Terminology”
(Linguagem e temas jurídicos brasileiros 4),
Advanced Course on “Brazilian Constitutional and Tax Law and on Brazilian
Legal Terminology” (Linguagem e temas
jurídicos brasileiros 4), Ludwig-MaximiliansUniversität München, Munich, Winter Term
2012/13.
Lecture “Introduction to Brazilian Constitutional and Tax Law and to Brazilian
Legal Terminology” (Linguagem e temas
jurídicos brasileiros 1), Ludwig-MaximiliansUniversität München, Munich, Summer
Term 2013.
Lecture “Current Questions of Brazilian
Law 1 (Aktuelle Fragen des brasilianischen
Rechts 1), Ludwig-Maximilians-Universität
Lecture “Current Questions of Brazilian
Law 1 (Aktuelle Fragen des brasilianischen
Rechts 1), Lecture, Ludwig-MaximiliansUniversity, Munich, Winter Term 2014/15.
Wolfgang Schön
Seminar “Grenzüberschreitende Unternehmen im Europäischen Steuer- und
Gesellschaftsrecht”, Ludwig-MaximiliansUniversität München, Munich, Winter Term
2011/12.
Grundlagenseminar “Verfassungsgerichtsentscheidungen zum Privatrecht“
(together with Prof. Dr. Dr. h.c. W. Schön, Dr.
A. Hellgardt, Dr. E. Röder), Ludwig-Maximilians-Universität München, Munich, Summer
Term 2013.
Grundlagenseminar “Verfassungsgerichtsentscheidungen zum Privatrecht” (together
with Dr. A. Hellgardt, Dr. C. Osterloh-Konrad,
Dr. E. Röder), Ludwig-Maximilians-Universität München, Munich, Summer Term
2013.
Lecture “Unternehmenssteuerrecht II –
Körperschaften und Umwandlungssteuerrecht” (together with Prof. Dr. Dr. h.c. W.
Schön), Ludwig-Maximilians-Universität
Lecture “Unternehmenssteuerrecht II – Körperschaften und Umwandlungssteuerrecht”
(together with Dr. C. Osterloh-Konrad),
Körperschaften und Umwandlungssteuerrecht” (together with Dr. E. Röder), LudwigMaximilians-Universität München, Munich,
Summer Term 2014.
Seminar “Europäisches Unternehmensrecht”, Ludwig-Maximilians-Universität
Erik Röder
Lecture “Unternehmenssteuerrecht II
– Körperschaften und Umwandlungssteuerrecht”, Ludwig-Maximilians-Universität
Recent Trends in EU Tax Law, Course for
the LL.M.-Program “International Tax Law”
(8 hours), Vienna University of Economics
and Business/Akademie der Wirtschaftstreuhänder, Vienna, Austria, May 2013.
Körperschaften und Umwandlungssteuerrecht” (together with Dr. C. OsterlohKonrad), Ludwig-Maximilians-Universität
Examinatorium Steuerrecht, LudwigMaximilians-Universität München, Munich,
Course “Multinational Enterprises and the
Law,” University of Florida – Levin College of
Law, Gainesville, USA Fall 2014.
Lecture “Europäisches und internationales
Unternehmensrecht”, Ludwig-MaximiliansUniversität München, Munich, Summer
Term 2014.
Lecture “European Tax Law”, Columbia Law
School, New York, USA, Fall Term 2014.
Seminar “Unternehmensbesteuerung und
Verfassungsrecht”, Ludwig-MaximiliansUniversität München, Munich, Winter Term
2014/15.
Lecture “Trends in EU Tax Law”, Wirtschaftsuniversität Wien, Austria, October 2014.
Amelie Singer
Tutorium zu “Grundkurs Zivilrecht” (Prof.
Lorenz), Ludwig-Maximilians-Universität
Propädeutische Übung zu “Grundkurs Zivilrecht” (Prof. Lorenz), Ludwig-MaximiliansUniversität München, Munich, Winter Term
2012/13.
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VI Awards and Prizes
Philipp Aigner
Academic Prize of the Munich Chamber
of Tax Consultants (Steuerberaterkammer
München), in 2013.
Andreas Eggert
Mitchell B. Carroll Prize 2014 by the International Fiscal Association (IFA) for his doctoral
thesis, in 2014.
Caroline Heber
The First Derivatives and Financial Instruments Award for the contribution “Overthe-Counter Derivative Markets in Light of
Regulation and Taxation” (together with
Christian Sternberg), in 2014.
Honorable Mention (2nd prize) in the competition for the Maurice Lauré Prize 2014, in
2014.
Christian Marquart
Academic Prize of the Munich Chamber
of Tax Consultants (Steuerberaterkammer
München), in 2014.
Promotion Prize of the Esche-SchümannCommichau-Prize for his doctoral thesis, in
2014.
Gerhard-Thoma Prize of Honuor (Fachinstitut der Steuerberater e.V.), in 2014.
Carlo Pohlhausen
University Price (2nd prize) of the “Deutsches
Aktieninstitut” for his doctoral thesis, in
2013.
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Philipp Redeker
Faculty Prize of the Law Faculty of LudwigMaximilians-Universität München for his
doctoral thesis, in 2012
Ph.D. Thesis Award of the Münchner
Universitätsgesellschaft, Gesellschaft von
Freunden und Förderern der Universität
München, e.V., in 2012.
Wolfgang Schön
The collective volume “Legal Rules for the
Closed Corporation” by Gregor Bachmann,
Horst Eidenmüller, Andreas Engert, Holger
Fleischer and Wolfgang Schön was selected
as one of the “Legal Books of the Year 2014”
in Germany.
Simon Stepper
Tax Law Moot Court Competition organized
by the Federal Fiscal Court (Bundesfinanz
hof). Member of the Winning Team, in
2012.
Christian Sternberg
The First Derivatives and Financial Instruments Award for the contribution “Overthe-Counter Derivative Markets in Light of
Regulation and Taxation” (together with
Caroline Heber), in 2014.
Jieyin Tang
Second Award of the Outstanding Achievement Prize for Social Sciences and Philosophy in Beijing for the best paper, in 2012.
VII Habilitation, Ph.D. and
Master’s Theses
Deborah Fries: Das Fiskusprivileg.
Carsten Hohmann: Die steuerliche Behand
lung von Verlusten einer Körperschaft bei
Unternehmenskäufen.
a) Supervised by Wolfgang Schön
Work in Progress
Alexander Hellgardt: Regulierung durch
Privatrecht.
Christine Osterloh-Konrad: Gestaltungsfreiheit im Steuerrecht.
Erik Röder: Nutzungsherausgabe und Nutzungsersatz.
b) External Supervisors
Mirja Hennigs: Europäische Grundfreiheiten
und steuerliches Verwaltungsverfahren.
Yasmin Holm: Steuerliche Gewinnermittlung
bei Betriebsstätten.
Šime Jozipović: Taxation and State Aid Law.
Leif Klinkert: Bilanzrechtliche Ausschüttungssperren.
Ulli Konrad: Gleichheit und Differentiation – Die Duale Einkommensteuer und der
Gleichheitssatz.
Stefan Kreutzer: Umwandlungen der
Personengesellschaften im steuerlichen
Rechtsvergleich.
Work in Progress
Nadia Lagdali: Kapitalmarktpublizität in den
arabischen Ländern.
Birke Häcker: Vermächtnis und Privatautonomie (Reinhard Zimmermann, Universität Regensburg, and Bucerius Law School).
Angelika Meindl-Ringler: Beneficial Ownership in International Tax Law.
Caroline Heber: Enhanced Cooperation Procedure and Tax Law (Wirtschaftsuniversität
Wien).
Bianca Mostacatto: Manager’s Duties with
Regard to Tax Planning: A Comparative Legal
Analysis.
Marta Oliveros Castelon: International Taxation of Service Income.
2. Ph.D. Theses
Thomas Poschenrieder: Kapitalschutz des
Agio im deutschen und englischen Recht.
a) Supervised by Wolfgang Schön
Susanne Risch: Gutgläubiger Erwerb und
der Rang von Rechten in der Genfer Wert
papierkonvention.
Work in Progress
Anastasios Andrianesis: Berichterstattung
über konzerninterne Transaktionen.
Martina Sunde: Freizügigkeitsabkommen
und Steuerrecht - Auslegung im Spannungsfeld von nationalem Recht, Unionsrecht und
Völkerrecht
Chiara Balbinot: Rechtsformneutralität und
Beihilferecht.
Ferdinand Blezinger: Gewinnverteilung bei
Personengesllschaften.
Mauritz von Einem: IP Migration – Besteuerung von IP Holdinggesellschaften.
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Completed Work
Andreas Eggert: Die Gewinnermittlung nach
dem Richtlinienvorschlag über eine Gemeinsame Konsolidierte KörperschaftsteuerBemessungsgrundlage – Vergleich mit der
Gewinnermittlung nach dem HGB, EStG und
den IFRS (Ludwig-Maximilians-Universität
München).
Kilian Eßwein: Privatautonome Gestaltung
der Vorstandshaftung (Ludwig-MaximiliansUniversität München).
Christian Garate: Research & Development
& Innovation Fiscal Incentive Provisions
(Ludwig-Maximilians-Universität München).
Christian Marquart: Gewinnverlagerungen
durch die gezielte Fremdfinanzierung von
Unternehmen und Konzepte zur Gegensteuerung – Eine rechtsvergleichende Untersuchung der Regelungen in Deutschland,
Australien, Kanada, den USA und dem
Vereinigten Königreich sowie zur Ausgestaltung de lege ferenda (Ludwig-MaximiliansUniversität München).
Carlo Pohlhausen: Unternehmensfinazierung am Kapitalmarkt in den arabischen
Staaten. (Ludwig-Maximilians-Universität
München)
Involvement in Foreign Doctoral Committees
Anzhela Yevgenyeva: Direct Taxation and
the Internal Market: Assessing Possibilities
for a More Balanced Integration (University
of Oxford, Oxford, UK).
Angharad Miller: An Examination of the
Approach to the Allocation of the Tax Base
from Cross-border Enterprise Services in the
OECD and UN Model Tax Conventions (Institute of Advanced Legal Studies, University of
London, London, UK).
b) External Supervisors
Work in Progress
Sara Dietz: Die Unabhängigkeit der EZB
(Peter Michael Huber, Ludwig-MaximiliansUniversität München).
Leopoldo Parada: Comparative Analysis of
the Problematic of Double Non-Taxation
(Francisco A. Garcia Prats, University of
Valencia).
Julian Schroeder: Der persönliche Anwendungsbereich der Prospekthaftung nach den
§§ 21 ff. WpPG und den §§ 20 ff. VermAnlG
(Mathias Habersack, Ludwig-MaximiliansUniversität München).
Amelie Singer: Das Common European Sales
Law im Licht des Internationalen Privatrechts (Marc-Philippe Weller, Universität
Freiburg).
Christian Sternberg: Formulary Apportionment under the CCCTB (Joachim Englisch,
Universität Münster).
Christine Watzinger (geb. Komisarczyk):
Rechtliche Probleme der Ausgestaltung
von Zahlungsverkehrssystemen in der
Wirtschafts- und Währungsunion (Christoph
Herrmann, Universität Passau).
Completed Work
Philipp Aigner: Die steuerliche Relevanz
des Wegfalls der Einkunftsquelle in § 20
EStG n.F. am Beispiel von Kapitalgesell
schaftsanteil und Kapitalforderung (Monika
Jachmann, Ludwig-Maximilians-Universität
München).
Andreas Gerten: Die steuerrechtliche
Behandlung von verdeckten Gewinnausschüttungen im internationalen Vergleich
(Joachim Hennrichs, Universität Köln).
Alexander Jehlin: Die Zinsschrankenregelung des § 4h EStG – ein rechtswissenschaftlicher und ökonomischer Beitrag
(Christian Seiler, Universität Tübingen).
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Natalia Paxinou: Die Besteuerung von
Zinserträgen an natürliche Personen aus
dem Blickwinkel Griechenlands (Theodore
Fortsakis, University of Athens, Greece).
3. Master’s Theses
Wolfgang Schön
Work in Progress
Máté Kovács: Mehrwertsteuerliche Aspekte
der Gesellschaftereinlagen in der Gründungsphase.
Renato Mendes Pellegrini Nahn: Die Sicherung des Steuergläubigers bei Wegzug
von Gesellschaften.
Yong Shang: Unilaterale „subject-to-tax/
switch-over“-Klauseln (§§ 8b Abs. 1 S. 3
KStG, 50d Abs. 8 und 9 EStG).
Completed Work
Šime Jozipović: Der Einfluss des EU-Beihilfenrechts auf das kroatische Steuerrecht.
Beatriz Nobre Nunes: Gesetzliche Vorgaben
für die Vorstandsvergütung bei Aktiengesellschaften (Zuständigkeiten, Angemessenheit,
Offenlegung).
Gianluca Perencin: Deutsch-italienische Erbschaftsbesteuerung: Doppelbesteuerung
und EU-Recht.
Nicole Rode: Internationale Steuerarbitrage
durch hybride Finanzinstrumente – Probleme und Lösungsvorschläge.
Arthur Troula Stüssi Neves: Vergleich von
Art. 24 OECD-MA mit EU-Diskriminierungs
verboten.
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103
C Events, Conventions, and Commit tees
I Events of the Department
1. Conferences and Other Events
4th International Diplomats Programme,
Internationale Diplomatenausbildung, Auswärtiges Amt, Max Planck Institute for Tax
Law and Public Finance, Munich, 20 April
2012.
Steuergesetzgebung und Steuersystematik,
Symposium zu Ehren von Herrn Ministerialdirigenten Eckehard Schmidt, Max Planck
Institute for Tax Law and Public Finance,
Munich, 4 May 2012.
III. Staff Retreat, MPI for Tax Law and Public
Finance, Schliersee, 6-8 May 2012.
Intangibles and Transfer Pricing, MPI for Tax
Law and Public Finance, INTR, Deutsche IFA,
Munich, 3-4 July 2012.
Munich, 25 February 2013.
Taxing Multinationals: The International
Allocation of the Tax Base, MPI for Tax Law
and Public Finance, Oxford University Centre
for Business Taxation, Saïd Business School,
Oxford, UK, 18 March 2013.
Munich-Sydney Conference on the Law and
Munich, 2-3 September 2013.
Finance, Kreuth, 22-24 September 2013.
2nd Max Planck European Postdoctoral
Conference on Tax Law, MPl for Tax Law and
Public Finance, Munich, 25-26 November
2013.
104
for Reform, Max Planck Institute for Tax Law
and Public Finance, INTR, Munich, 24-25
January 2014.
Tax Law, Max Planck Institute for Tax Law
and Public Finance, Munich, 24 February
2014.
2. MPI Lecture Series
Peter Melz, Professor, Stockholm University,
Sweden, Earned Income or Capital Income?
– Some Structural Questions Concerning
Classification, 26 March 2012.
Marc Desens, Professor, Universität Leipzig,
Reformvorschläge zur Vermeidung der
Umsatzsteuerdefinitivbelastung bei Körperschaften des öffentlichen Rechts, 17 April
2012.
Tina Ehrke-Rabel, Professor, Karl-FranzensUniversität Graz, Austria, Auslegung des
Steuerrechts im Spannungsfeld zwischen
unionsrechtlichen Vorgaben und nationalen
Normen, 18 June 2012.
Graeme Cooper, Professor, University of
Sydney, Sydney Law School, Australia, International Experience with Statutory General
Anti-Avoidance Rules, 11 September 2012.
Michael Droege, Professor, Johannes
Gutenberg-Universität Mainz, Die Kodifikationsidee in der Steuerrechtsordnung, 24
September 2012.
Roland Ismer, Professor, Universität Erlangen-Nürnberg, Grundfragen der Besteuerung
des Finanzsektors, 15 October 2012.
Johannes Kippenberg, Verlag C.H. Beck, 20
Jahre Zeitschrift IStR, 4 December 2012. Andreas Musil, Professor, Universität Potsdam, Die Sicht der Steuerrechtswissenschaft
auf das Verfassungsrecht, 12 December
2012.
Luis Eduardo Schoueri, LL.M., Professor, São
Paulo, Brazil, Tax Sparing: A Reconsideration
of the Reconsideration, 14 January 2013.
Deborah Schanz, Professor, Ludwig-Maximilians-Universität München, Tax Attractiveness and the Location of German-Controlled
Subsidiaries, 4 February 2013.
Hugh J. Ault, Professor, Boston College Law
School, Boston, USA, Some Reflections on
the OECD and the Sources of International
Tax Principles, 2 May 2013.
Michael Dirkis, Professor, Sydney Law
School, Sydney, Australia, Base Erosion and
Profit Shifting – The Australian Response, 22
July 2013.
Lee A. Sheppard, Tax Analysts, Falls Church,
USA, The Twilight of the International Consensus, 26 November 2013.
Yariv Brauner, Professor, Levin College of
Law, Gainsville, USA, International Tax Policy
and Development, 5 December 2013.
Georg Kofler, LL.M., Professor, Linz, Austria,
Ist der Spuk des Europäischen Steuerrechts
bald vorbei?, 4 February 2014.
Juliane Kokott, Professor, Gerichtshof der
Europäischen Union, Luxemburg, Der
unionsrechtliche allgemeine Gleichheitssatz
im Europäischen Steuerrecht, 3 April 2014.
Hanno Kube, Professor, Universität Mainz,
Die Schwierigkeit judikativer Systembildung
im Europäischen Ertragsteuerrecht, 5 May
2014.
Ruth Mason, Professor, University of Virginia, Charlottesville, USA, Citizenship Taxation,
22 May 2014.
Miranda Stewart, Professor, University of
Melbourne, Australia, Past and Future of the
Tax State, 8 July 2014.
Michael Lang, Professor, Wirt-schaftsuniversität Wien, Vienna, Austria, Ist die
Rechtsprechung des EuGH zu den finalen
Verlusten am Ende?, 6 October 2014.
Alexander Rust, LL.M., Professor, Wirtschaftsuniversität Wien, Vienna, Austria,
Der BEPS-Aktionsplan zu den hybriden
Finanzinstrumenten und seine Vereinbarkeit
mit den Gleichbehandlungsgeboten, 4 November 2014.
Wolfgang Schön, Professor, MPI for Tax Law
and Public Finance, Neutralität und Territorialität – Gegensätze oder Grundsätze des
Europäischen Steuerrechts?, 3 December
2014.
3. Guest Lectures
Daniel Deak, Professor, University of Budapest, Hungary, and Alexander Hellgardt,
Special Taxation of Financial Enterprises
after the Global Financial Crisis (Bank Levy),
7 February 2012.
Chloe Burnett, Barrister and Adjunct
Lecturer, University of Sydney, Sydney, Australia, Intra-group Debt at the Crossroads:
Stand-alone vs Worldwide Approach, 14
January 2013.
Alexia Kardachaki, IFA Researcher, IBFD,
Amsterdam, Netherlands, VAT Aspects of
Outsourcing, and Tax Aspects of International Non-Tax Agreements, 23 January 2013.
Ayelet Shachar, Professor, University of
Toronto, Faculty of Law, Toronto, Canada,
Olympic Citizienship: Migration and the
Global Race for Talent, 18 February 2013.
James S. Halpern, Judge at the U.S. Tax
Court, Washington, USA, The U.S. Tax Court
and its Role in U.S. Tax Litigation, 22 July
2013.
Lisa Evers, Centre for European Economic
Research (ZEW), Mannheim, Intellectual
Property Box Regimes: Effective Tax Rates
and Tax Policy Considerations, 27 November
2013.
Jens C. Dammann, Professor, The University
of Texas, Austin, USA, Perspectives for Transatlantic Scholarship, 2 July 2014.
Events, Conventions, and Committees
105
105
4. Münchner Gesprächskreis
Unternehmensrecht
Dieter Mayer, Professor, Notar, München,
Der verschmelzungsrechtliche Squeeze out
– neue Gestaltungsmöglichkeiten für den
Hauptaktionär, 28 March 2012.
Klaus J. Hopt, Professor, MPI for Comparative and International Private Law, Hamburg,
and Konrad Wartenberg, General Counsel,
Axel Springer AG, Berlin, Der Deutsche Corporate Governance Kodex: Grundlagen und
Praxisfragen, 26 July 2012.
Lars Klöhn, Professor, Ludwig-MaximiliansUniversität München, and Michael Brellochs, Allen & Overy, München, Ad-HocPublizität und Insiderrecht, 26 November
2012.
Michael Kort, Professor, Universität Augsburg, and Georg Annuß, Professor, Linklaters LLP, Munich, Altersgrenzen für Leitungspersonen in Unternehmen, 15 April 2013.
Karsten Schmidt, Professor, Bucerius Law
School, Hamburg, Die “Innenkommanditgesellschaft” – wirklicher Verband und
virtueller Rechtsträger, 18 September 2013.
Jochem Reichert, Professor, Schilling – Zutt
– Anschütz, Mannheim, and Helmut Krenek,
Vorsitzender Richter am Landgericht, Munich, Rechtsfragen der Business Combination Agreements, 24 March 2014.
Gerhard Wagner, Professor, Humboldt
Universität, Berlin, and Oliver Sieg, Noerr
LLP, Düsseldorf, Reform der Organhaftung,
18 June 2014.
Martin Burgi, Professor, Ludwig-Maximilians-Universität München, Das künftige
Vergabe- und Privatisierungsrecht als
Herausforderung für Unternehmen, 1 December 2014.
5. Brownbag-Lunches
Mauritz von Einem, Current Problems and
the Reform of the Directive on Interest and
Royalty Payments, 5 January 2012.
Birke Häcker, Die geplante EU-Verordnung
zur grenzüberschreitenden vorläufigen Kontopfändung, 9 February 2012.
Christoph Weber, Kapitalmarktinformationshaftung und gesellschaftsrechtliche
Kapitalbindung, 12 April 2012.
Federica Pitrone, Environmental Taxation:
The Italian Case, 10 May 2012.
Andreas Gerten, Angemessenheit und Steuern: Verdeckte Einkommensverwendung
bei Kapitalgesellschaften im internationalen
Vergleich, 31 May 2012.
Angelika Meindl, Das Rückwirkungsverbot
– ein Vergleich der Rechtsprechnung des
BVerfGs und des EGMR, 28 June 2012.
Kilian Eßwein, Privatautonome Gestaltung
der Vorstandshaftung, 26 July 2012.
Andreas Eggert, Die Gewinnermittlung nach
dem Richtlinienvorschlag über eine gemeinsame konsolidierte KörperschaftsteuerBemessungsgrundlage – Vergleich mit der
Gewinnermittlung nach dem HGB, EStG und
den IAS/IFRS, 11 October 2012.
Kai Purnhagen, Warum hat es die ökonomische Analyse des Rechts in Europa so
schwer? Eine sozio-kulturelle Sicht, 8 November 2012.
Susanne Risch, Die Regelung des redlichen
Erwerbs in der Genfer Wertpapierkonvention, 6 December 2012.
Thomas Poschenrieder, Die Vale-Entscheidung des EuGH, 10 January 2013.
Yasmin Holm, Verfassungswidrigkeit der
Mindestbesteuerung, 7 February 2013.
Martina Sunde, Muss der EuGH bei der
Beurteilung des Freizügigkeitsabkommens
seine eigene Rechtsprechung ignorieren?,
7 March 2013.
106
Alexander Hellgardt, Rechtsfortbildung
durch den EuGH und ihre Umsetzung ins
nationale Recht – das Weber/Putz-Urteil,
4 April 2013.
Ewa Bienkowska, Taxation for Development – Tax Incentives for Technology Transfer to
the LDCs, 13 June 2013.
Jonathan Schindler, Die Hofnachfolge als
erbrechtlicher Sonderfall, 4 July 2013.
Angelika Meindl, Beneficial Ownership in
den USA, 1 August 2013.
Daniel Dürrschmidt, Nichtanwendungserlasse und Nichtanwendungsgesetze – ein
steuerrechtliches Phänomen, ein verfassungsrechtliches Problem?, 12 September
2013.
Birke Häcker, Das Common Law: Entwicklung, Charakteristika und Verhältnis zum Ius
Commune, 10 October 2013.
Jörg Schwarz, Vom Danegeld zum Florentiner Kataster. Konzeptionen des Steuerrechts im europäischen Mittelalter und ihre
Umsetzung, 14 November 2013.
Carina Frahm, Tax Matters and International
Investment Law, 12 December 2013.
Erik Röder, Entstrickungsbesteuerung im
Binnenmarkt nach National Grid Indus: Bestandsaufnahme und Perspektiven,
9 January 2014.
Chiara Balbinot, Die Trennungstheorie bei
der Besteuerung von Optionsgeschäften,
6 February 2014.
Caronie Heber and Christian Sternberg,
Der außerbörsliche Derivatemarkt im Lichte
der EMIR-Clearing-Pflicht und der Finanztransaktionssteuer, 20 March 2014.
Christine Komisarczyk, Rechtliche Probleme
der Ausgestaltung des Zahlungsverkehrssystems TARGET2 in der Europäischen
Wirtschafts- und Währungsunion,
10 April 2014.
Leopoldo Parada, Automatic Exchange of
Financial Information, FATCA and Intergovernmental Agreements (IGAs), 8 May 2014.
Hugh J. Ault, Professor, Perspective on BEPS,
12 June 2014.
Jean-Nicolas Druey, Professor, Geheim- und
Gemeinsphäre, 9 July 2014.
Stefano Ronco, The Notion of Business
Enterprise in EU Direct Taxation in Light of
the Case-law on Italian Bank Foundations
and Co-operative Entities, 17 July 2014.
Deborah Fries, Die steuerrechtliche Haftung
des Geschäftsführers in der Krise und Insolvenz: Ein Fiskusprivileg im Rechtsvergleich,
2 October 2014.
Wolfgang Schön, Professor, Beraterhaftung
und hypothetischer Inzidentprozess,
13 November 2014.
Carmel Said Formosa, Financial Transaction
Tax: A Comparative Analysis of Transaction
Taxes Across Europe, 11 December 2014.
6. Discussion Rounds
Andreas Eggert, BFH Urteil v. 12.07.2012
(=DStR 2012, 2058 = BB 2012, 2864) – Können Missbrauchsregelungen Missbrauch
verhindern?, 21 February 2013.
Ferdinand Blezinger, BGH Urteil v.
10.07.2012 (=NJW 2012, 3439 = ZIP 2012,
1552) – Garantenpflicht von Geschäftsführern, 21 February 2013.
Christine Osterloh-Konrad, BGH Urteil v.
16.10.2012 – II ZR 251/10 (BGH NZG 2013,
57) – Änderung von gesellschaftsrechtlichen
Klauseln mit Mehrheitserfordernissen, 21
March 2013.
Yasmin Holm, BFH Vorlagebeschluss v.
27.09.2012 – II R 9/11 – Verfassungswidrigkeit des ErbStG, 21 March 2013.
Thomas Poschenrieder, BFH Urt. v.
02.08.2012, IV R 41/ – Unentgeltliche Übertragung von Mitunternehmeranteilen, 18
April 2013.
Thomas Poschenrieder, BGH Urt. v.
24.01.2012, II ZR 109/11 – Einziehung von
GmbH-Geschäftsanteilen, 18 April 2013.
107
107
Chiara Balbinot, Kommissionsentscheidung
v. 26.01.2011, C-(2011) 275 – Beihilfeverbot
vs. Unternehmenssanierung: Diskussion
anhand von Sanierungsklausel und Sanierungserlass, 16 May 2013.
Thomas Poschenrieder, BGH Urteil v.
12.03.2013 – II ZR 179/12 (=DStR 2013,
982): Rechtsfolgen bei Verstoß gegen
§ 57 AktG, 16 May 2013.
15.11.2012, IX ZR 205/11 – Insolvenzanfechtung von Beraterhonoraren, 20 June 2013.
Yasmin Holm, BFH Urteil v. 30.01.2013, II
R 6/12 – Verhältnis verdeckte Gewinnausschüttung – Schenkungssteuer, 20 June
2013.
Christine Osterloh-Konrad, BFH Beschl. v.
31.01.2013, GrS 1/10 – Aufgabe des subjektiven Fehlerbegriffs, 18 July 2013.
Alexander Hellgardt, BGH Beschl. v.
23.04.2013, II ZB 7/09 – Insiderinformation
bei zeitlich gestrecktem Sachverhalt, Daimler/Geltl, 18 July 2013.
Julian Schroeder, BGH Urteil v. 21.02.2013,
III ZR 139/12 (=NJW 2013, 1877) – Prospekthaftung eines Wirtschaftsprüfers, 26
September 2013.
Daniel Blum, Österreichischer VwGH Urteil
v. 25.09.2013 – Schumacker-Entscheidung
des EuGH in Drei-Staaten-Konstellationen,
26 September 2013.
Christian Sternberg, EuGH Urteil v.
03.10.2013, C-282/12 – Zulässigkeit von
Zinsschranken, 17 October 2013.
Erik Röder, BGH Urteil v. 16.4.2013, II ZR
118/11 – Anspruch der KG gegen den Kommanditisten auf Erstattung der Kapitalertragsteuer, 17 October 2013.
8.10.2013, II ZB 26/12 – Kein Anspruch
auf Barabfindung beim regulären Delisting
(Macrotron II), 21 November 2013.
Yasmin Holm, EuGH Urteil v. 7.11.2013 –
Grenzüberschreitende Verlustnutzung, 21
November 2013.
108
Christian Sternberg, BFH Urteil v.
24.10.2012, IX R 36/11 – Verfassungsmäßigkeit von § 17 EStG, 19 December 2013.
Christine Osterloh-Konrad, EuGH Urteil v.
18.7.2013, C-147/12 – Zuständigkeit für
gesellschaftsrechtliche Gläubigerschutzansprüche nach der EuGVVO, 19 December
2013.
Thomas Poschenrieder, OLG München Beschl. v. 16.2.2013 – Keine Zuständigkeit des
Baseler Notars zur Einreichung der Gesellschafterliste beim Handelsregister,
23 January 2014.
Christine Osterloh-Konrad, EuGH Urteil
v. 3.10.2013, C 322/12 – Bilanzierung bei
offenkundig nicht wertangemessenen Anschaffungskosten, 23 January 2014.
Ferdinand Blezinger, LG München I Urteil v.
04.03.2013 – 15 O 8167/12 – Zur Unwirksamkeit von Rentenklauseln in Sozietätsverträgen nach § 723 Abs. 3 BGB, 20 February
2014.
Julian Schröder: BGH Urteil v. 20.9.2011, II
ZR 234/09 – Sorgfaltspflichten des Vorstands
einer Aktiengesellschaft und Voraussetzungen einer Enthaftung, 24 April 2014.
Birke Häcker, BFH Urteil v. 18.7.2013, II R
45/11 – Kettenschenkungen als erbschaftssteuerliches Gestaltungsmittel, 24 April 2014.
Leopoldo Parada, Schweizer BVerwG Urteil
v. 06.01.2014 – A-5390/2013: Amtshilfegesuch der US-amerikanischen Steuerbehörden; Anforderungen an zulässige Gruppenanfragen, 22 May 2014.
Erik Röder, BGH Urteil v. 19.11.2013 – II ZR
383/12: Anwendung der Grundsätze der
fehlerhaften Gesellschaft auf mehrgliedrige
stille Gesellschaft, 22 May 2014.
Anastasios Adrianesis, Die Bedeutung der
Marktunüblichkeit im Sinne von § 285 Nr. 21
HGB, 27 June 2014.
Deborah Fries, BFH Urteil v. 16.05.2013, IV
R 23/11 – Einkommensteuer als sonstige
Masseverbindlichkeit bei Veräußerung
von mit Absonderungsrechten belasteten
Wirtschaftsgütern durch den Insolvenzverwalter, 26 June 2014.
Christine Osterloh-Konrad, BVerfG Beschl. v.
17.12.2013, I BvG 5/08 – Echte Rückwirkung
durch Klarstellung geltenden Rechts, 25
September 2014.
Stefan Kreutzer, Die Übertragung eines
Wirtschaftsguts auf eine Personengesellschaft gegen Teilentgelt oder teilprivilegiertes Mischentgelt, 25 September 2014.
Thomas Poschenrieder, BGH Urteil v.
15.10.2007, II ZR 216/06 – Schuldrechtliche
Vereinbarungen über Agio und dessen
Einforderung in der Insolvenz, 30 October
2014.
Yasmin Holm, Zur Anwendbarkeit von § 1
Abs. 4, 5 AStG auf ausländische Schwesterbetriebsstätten, 30 October 2014.
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109
II Participation at Conferences,
Congresses, and Conventions
Property Law Discussion Group Meeting, Law Faculty, Oxford University, Oxford,
UK, February 2012 (Häcker).
2012
Targeted Killing, Law Faculty Seminar, Oxford University, Oxford, UK, February 2012
(Häcker).
Organschaften “über die Grenzen”, Vortragsveranstaltung Bayerische IFA, Bundesfinanzhof, Munich, January 2012 (Schön).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, January 2012
(Hellgardt, Röder).
Designing Company Law Acts in Europe,
Podiumsdiskussion, Center for Advanced
Studies der Ludwig-Maximilians-Universität
München, Munich, January 2012 (Häcker,
Schön).
Der politische Mord, Grundlagenseminar
Prof. Dr. P. Wittig, Ludwig-MaximiliansUniversität München, Munich, January 2012
(Häcker).
Die neue Erbrechtsverordnung, Forschungsstelle für Notarrecht, Ludwig-MaximiliansUniversität München, Munich, January 2012
(Poschenrieder).
CCCTB and Third Countries, Institute for
Austrian and International Tax Law of
Wirtschaftsuniversität Wien, Vienna, Austria, January 2012 (Röder).
Perspektiven bei der Einkommensbesteuerung, Klausurtagung der Arbeitsgruppe
Finanzen der CDU/CSU-Bundestagsfraktion,
Bayerische Vertretung, Berlin, February
2012 (Schön).
Taxation of the Financial Sector, Seminar,
February 2012 (Hellgardt).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, February 2012
(Häcker).
Neill Lecture, All Souls College, Oxford University, Oxford, UK, February 2012 (Häcker).
Sir Jeremy Lever Lecture, Law Faculty, Oxford University, Oxford, UK, February 2012
(Häcker).
Workshop on Empirical Methods in Public
Finance, MPI for Tax Law and Public Finance,
Munich, March 2012 (Schön).
Tax Measures as State Aid – The Aftermath
of the Gibraltar Case, Academy of European
Law, Brussels, Belgium, March 2012 (Balbinot).
Mysterium „Gesetzesmaterialien“, MPI for
Comparative and International Private Law,
Hamburg, March 2012 (Hellgardt).
Lecture Prof. Dr. C. Fuest, Queen’s College,
Oxford University, Oxford, UK, March 2012
(Häcker).
European Takeover Regulation, Oxford University, Oxford, UK, April 2012 (Hellgardt).
Richard Musgrave Lecture, CESifo Group,
Munich, April 2012 (Kane, Schön).
ZHR-Herausgebersitzung, Frankfurt, May
2012 (Schön).
III. Staff Retreat and Workshop MPI for Tax
Law and Public Finance, Schliersee, May
2012 (Balbinot, Eggert, Eßwein, Furuseth,
Häcker, Kane, Klinkert, Komisarczyk, Meindl, Mostacatto, Oliveros Castelon, OsterlohKonrad, Pitrone, Röder, Schön, Sunde).
63. Steuerrechtliche Jahresarbeitstagung,
Unternehmen 2012, Wiesbaden, May 2012
(Balbinot, Komisarczyk, Meindl, Röder).
EATLP-Congress 2012, Erasmus University
Rotterdam, Rotterdam, Netherlands, May
2012 (Schön).
Beneficial Ownership, Institut für Österreichisches und Internationales Steuerrecht,
Vienna, Austria, May 2012 (Furuseth,
Meindl).
110
Der Schutz des Immaterialgüterrechts im
Internet in der Rechtsprechung des EuGH,
Lecture Prof. V. Trstenjak, Max Planck
Campus for Legal and Economic Research,
Munich, May 2012 (Hellgardt).
Tax Treaty Case Law around the Globe, Tilburg University, Tilburg, Netherlands, June
2012 (Furuseth).
Antrittsvorlesung J. Waldron, Oxford University, Oxford, UK, May 2012 (Hellgardt).
Interdisziplinärer Förderkongress Junge
Wissenschaft und Praxis, Hanns Martin
Schleyer-Stiftung / Robert Bosch Stiftung,
Leipzig, June 2012 (Röder).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, May 2012
(Hellgardt).
Discussion Meeting on the UK Supreme
Court Decision in the FII Litigation, One Essex Court, London, UK, June 2012 (Häcker).
Europa als Rechtsgemeinschaft, Universität
Augsburg, Augsburg, May 2012 (Komisarczyk, Mostacatto).
Intangibles and Transfer Pricing, Interdisciplinary Conference, MPI for Tax Law and
Public Finance, INTR, Deutsche IFA, Munich,
July 2012 (Röder).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, June 2012
(Hellgardt).
Antrittsvorlesung Prof. Maultzsch / Prof.
Tröger, Goethe-Universität Frankfurt, Frankfurt, June 2012 (Hellgardt).
IFSt-Jahrestagung 2012, Weichenstellungen
der deutschen und europäischen Steuerpolitik, Berlin, June 2012 (Eggert).
Steuerpolitik im Umfeld neuer Fiskalinstitutionen und Abstimmungsverfahren, Kick-Off
Meeting, Mannheim, June 2012 (Röder,
Sunde).
540. Stiftungsfest der Ludwig-MaximiliansUniversität München, Munich, June 2012
(Kindler, Redeker, Schön).
The GREIT Lisbon Summer Course on State
Aid, Group for Research on European and
International Taxation, Lisbon, Portugal,
June 2012 (Oliveros Castelon).
EU Tax Policy Conference, Salão Nobre,
Reitoria da Universidade de Lisboa, Lisbon,
Portugal, June 2012 (Oliveros Castelon).
Montagsseminar, MCG Ludwig-MaximiliansUniversität München, Munich, June 2012
(Hellgardt).
Angleichung der Unternehmensbesteuerung
zwischen Deutschland und Frankreich –
neuer Anstoß für eine Harmonisierung in
Europa?, 43. Berliner Steuergespräche, Berlin, June 2012 (Eggert).
Vorweggenommene Vermögensübertragung
unter Ausschluss von Pflichtteilsansprüchen,
Tagung der Forschungsstelle für Notarrecht,
Munich, July 2012 (Häcker).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, July 2012
(Hellgardt).
Challenging Orthodoxy, Obligations VI Conference, University of Western Ontario Law
School, London/Ontario, Canada, July 2012
(Häcker).
Antrittsvorlesung Prof. Dr. P. Hellwege,
Universität Augsburg, Augsburg, July 2012
(Häcker).
Rhetorikseminar des Mentoring-Programms
der Ludwig-Maximilians-Universität
München (Juristische Fakultät), Frauenchiemsee, July 2012 (Häcker).
23. Jahrestagung der Gesellschaft Junger
Zivilrechtswissenschaftler, Berlin, September
2012 (Röder).
37. Jahrestagung Internationales Steuerrecht, Deutsche Steuerjuristische Gesellschaft, Linz, Austria, September 2012 (Balbinot, von Einem, Komisarczyk, Oliveros
Castelon, Röder, Schön, Sunde).
69. Deutscher Juristentag, Munich, September 2012 (Eßwein, Komisarczyk, Schön,
Singer).
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111
Genossenschaftsrecht in Bayern – historische Entwicklungen, 9. Tagung der Gesellschaft für Bayerische Rechtsgeschichte,
Munich, September 2012 (Poschenrieder).
66th Congress of the International Fiscal
Association, Boston, USA, September 2012
(Röder, Schön).
Jahreskonferenz der Deutsch-Amerikanischen Juristen-Vereinigung, New York, USA,
October 2012 (Stepper).
1. Wiener Unternehmensrechtstag, Vienna,
Austria, October 2012 (Hellgardt).
Akademische Feier aus Anlass des 60.
Geburtstages von Reinhard Zimmermann,
Hamburg, October 2012 (Schön).
Forschung 2020 – Perspektiven des Wissenschafts- und Forschungssystems, Fachkongress der SPD-Bundestagsfraktion, Berlin,
October 2012 (Schön).
Semestereröffnungsvortrag des CVM mit
Heiner Geißler, Ludwig-Maximilians-Universität München, Munich, October 2012
(Hellgardt).
Symposium zur Geschichte der MPG, Berlin,
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, October 2012
(Osterloh-Konrad).
2nd Annual Meeting of the Alumni Association of the MPI for Tax Law and Public
Finance, Munich, November, Munich, November 2012 (Häcker, Hellgardt, OsterlohKonrad, Schön).
Steuerliche Faktoren bei M&A-Transaktionen und ihre Auswirkung auf Strukturierung und Vertragsgestaltung, BeckAkademie-Seminar, Munich, November
2012 (Balbinot).
Ertragsteuerliche Vorschriften als europarechtswidrige Beihilfen?, Vortragsveranstaltung IFA Berlin-Brandenburg, Berlin,
November 2012 (Balbinot).
112
Bestandsaufnahme zur Erbschaftsteuer,
45. Berliner Steuergespräche, Berlin, November 2012 (Balbinot).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, November
2012 (Hellgardt, Osterloh-Konrad, Röder).
Zehn Jahre Schuldrechtsmodernisierung,
Munich, November 2012 (Osterloh-Konrad,
Hellgardt).
Forschungsseminar, Ludwig-MaximiliansUniversität München, Munich, November
2012 (Hellgardt).
Vermeidung der Doppelbesteuerung und ihre
Grenzen, 29. Hamburger Tagung zur internationalen Besteuerung, Hamburg, December
2012 (von Einem, Holm).
Steuerpolitik im Umfeld neuer Fiskalinstitutionen und Abstimmungsverfahren, Kick-Off
Meeting, Centre for European Economic
Research (ZEW), Mannheim, MPI for Tax
Law and Public Finance, Munich, December
2012 (Röder, Schön, Sunde).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, December
2012 (Hellgardt, Osterloh-Konrad).
2013
Räuber, Banditen und Piraten, Interdisziplinäres Grundlagenseminar zu organisiertem Verbrechen und Bandenkriminalität,
Herrsching, January 2013 (Häcker).
Developing a Tax Environment for Growth
and Competitiveness, Institute for Austrian
and International Tax Law, WU/Association
Internationale de Droit Economique, Vienna,
Austria, January 2013 (Osterloh-Konrad).
Versicherungsrecht aus der Perspektive
des OLG, Netzwerk Jura München, LudwigMaximilians-Universität München, Munich,
January 2013 (Poschenrieder).
ZHR – Symposion 2013, Gesellschafts- und
Kapitalmarktrecht, Königstein, January 2013
(Röder).
75th Anniversary of the International Fiscal
Association, The Hague, Netherlands, February 2013 (Schön).
Verleihung des Berliner Wissenschaftspreises des Regierenden Bürgermeisters von
Berlin, Berlin, February 2013 (Schön).
Festschriftübergabe an Michael HoffmannBecking, Düsseldorf, February 2013 (Schön).
Munich, February 2013 (Andrianesis, Ault,
Blezinger, Eggert, Eßwein, Hellgardt, Holm,
Jozipović, Martinengo, Mostacatto, Oliveros Castelon, Osterloh-Konrad, Poschenrieder, Risch, Schön, Sunde).
Crowdinvesting-Symposium 2013, Marktentwicklung und Regulierungsperspektive,
Munich, February 2013 (Komisarczyk).
Betreutes Wohnen, Forschungsstelle für
Notarrecht, Ludwig-Maximilians-Universität
München, Munich, February 2013
(Poschenrieder).
Rechtsphilosophische und rechtstheoretische Grundlagen eines europäischen Vertragsrechts, Junges Kolleg der Bayerischen
Akademie der Wissenschaften, Munich,
February 2013 (Singer).
Steuerpolitik im Umfeld neuer Fiskalinstitutionen und Abstimmungsverfahren, Internal
Workshop, Centre for European Economic
Research (ZEW), Mannheim, February 2013
(Sunde).
A Strategy for Free Speech in an Interconnected World, Timothy Garton Ash, CONVOCO Lecture 2013, London, UK, March
2013 (Schön).
Allocation of the Tax Base, Max Planck Institute for Tax Law and Public Finance, Saïd
Business School, Oxford, UK, March 2013
(Eggert, Häcker, Hellgardt, Holm, Oliveros
Castelon, Osterloh-Konrad).
Annual Meeting of the Harvard Law School
Association of Germany, Frankfurt, March
2013 (Hellgardt).
Market Efficiency and the U.S. MortgageBacked Securities Crisis, Professor Reinier
Kraakman, Frankfurt, March 2013 (Hellgardt).
8. Deutscher Erbrechtstag, Arbeitsgemeinschaft Erbrecht des Deutschen Anwaltvereins, Berlin, March 2013 (Osterloh-Konrad).
52. Münchner Steuerfachtagung, Munich,
March 2013 (Osterloh-Konrad).
ZHR Editorial Board, Frankfurt, April 2013
(Schön).
The Employment and Social Situation –
Europe’s Social Crisis: Is there a Way Out?,
Lászlá Andor, MPI for Social Law and Social
Policy, Munich, April 2013 (Schön).
Bifurkation im deutschen Patentstreitverfahren – eine Nemesis für Patentverletzer
und -inhaber?, Dietmar Harhoff, MPI for
Intellectual Property and Competition Law,
Patentrechtszyklus 2013, Munich, April 2013
(Schön).
113
113
Die deutsche Verhandlungsgrundlage für
Doppelbesteuerungsabkommen, Panel Discussion, Federal Ministry of Finance, Berlin,
April 2013 (Martinengo).
13th Annual Tax Planning Strategies: US
and Europe, London, UK, April 2013 (Bienkowska).
Future Frontiers in Political Economy
Research and Theory, MPI for the Study of
Societies, Cologne, April 2013 (Hellgardt).
D-A-CH Steuer-Kongress 2013, Hotel Marriott, Vienna, Austria, April 2013 (Sunde).
64. Steuerrechtliche Jahresarbeitstagung
Unternehmen 2013, Arbeitsgemeinschaft
der Fachanwälte für Steuerrecht e.V.,
Wiesbaden, May 2013 (Balbinot, Holm,
Komisarczyk, Osterloh-Konrad).
Relaunching Europe, XII. Munich Economic
Summit, Munich, May 2013 (Schön).
EATLP Congress 2013, European Association
of Tax Law Professors, Lisbon, Portugal, May
2013 (Balbinot).
United Nations, ECOSOC, Session Moderator, Special Session on International Cooperation in Tax Matters, New York, USA, May
2013 (Ault).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, May 2013
(Osterloh-Konrad).
3. Zukunftsfakultät – “Interdisziplinarität”,
Recht im Kontext: Rechtskulturen, Institute
for Advanced Study, Berlin, June 2013
(Häcker).
Fragen des Deutschen Corporate Governance Kodex (Rechtsnatur, Sanktionen
bei fehlerhafter Entsprechenserklärung),
Professor Habersack, Münchener Juristische
Gesellschaft, Munich, June 2013 (Hellgardt).
Steuerhistorisches Symposium der
Deutschen Steuerjuristischen Gesellschaft
e.V., Frankfurt am Main, June 2013 (Holm,
Osterloh-Konrad).
114
International Private Law in China and Europe, MPI for Comparative and International
Private Law, Hamburg, June 2013 (Singer).
Intensivierung der internationalen Zusammenarbeit in Steuerfragen, Bayerisches
Staatsministerium der Finanzen, Munich,
July 2013 (Schön).
Convoco Forum 2013, Rechnen mit dem
Scheitern: Individuelle und kollektive Strategien in ungewissen Zeiten, Salzburg,
Austria, July 2013 (Schön).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, July 2013
(Osterloh-Konrad).
Association, Copenhagen, Denmark, August
2013 (Schön, Xiong).
Erneuerung des Steuerrechts, 38. Jahrestagung der Deutschen Steuerjuristischen
Gesellschaft e.V., Humboldt Universität zu
Berlin, Berlin, September 2013 (Balbinot,
Komisarczyk, Meindl, Sternberg, Sunde).
Munich-Sydney Conference on the Law and
Munich, September 2013 (Blum, Häcker,
Komisarczyk, Meindl, Oliveros Castelon,
Schroeder, Sternberg, Sunde).
34. Tagung für Rechtsvergleichung, Recht
und Rechtsvergleichung in der Finanzkrise,
Gesellschaft für Rechtsvergleichung, Marburg, September 2013 (Häcker).
Finance, Kreuth, September 2013 (Blezinger,
Häcker, Jozipović, Komisarczyk, Lindeberg,
Meindl, Mostacatto, Oliveros Castelon,
Poschenrieder, Röder, Singer, Schroeder,
Sunde, Xiong).
International Tax Principles in BRICs and
OECD Countries: Divergences and Convergences, Brazilian Tax Law Institute (IBDT),
Law Faculty of the University of São Paulo,
Brazilian School for Judges (EMAG), and
International Fiscal Association (IFA), São
Paulo, Brazil, September 2013 (Oliveros
Castelon).
The Economics of Formal & Informal Institutions, Workshop, Marburg Centre for Institutional Economics, Marburg, September 2013
(Sternberg).
7. ErbR-Tagung, Vermögensnachfolge, Arbeitsgemeinschaft Erbrecht des Deutschen
Anwaltvereins, Munich, October 2013
(Häcker, Osterloh-Konrad).
Lecture by Prof. H. MacQueen to Mark the
Publication of “Judge and Jurist: Essays in
Memory of Lord Rodger of Earlsferry”, University of Oxford, Oxford, UK, October 2013
(Häcker).
5th Brazilian Congress on International Tax
Law, Brazilian Tax Law Institute (IBDT) and
Law Faculty of the University of São Paulo,
São Paulo, Brazil, October 2013 (Oliveros
Castelon).
IStR-Jahrestagung, Berlin, October 2013
(Holm).
Niedriglohn und Mindestlohn, Dr. Christian
Picker, Zentrum für Arbeitsbeziehungen
und Arbeitsrecht, Munich, October 2013
(Hellgardt).
Grenzen steuerlicher Gestaltungsfreiheit
– Verhältnis des § 42 AO zu speziellen Missbrauchsvermeidungsvorschriften, Münchner
Unternehmenssteuerforum e.V., Munich,
October 2013 (Osterloh-Konrad).
Steuerpolitik im Umfeld neuer Fiskalinstitutionen und Abstimmungsverfahren, Internal
Workshop, PAKT, Speyer, October 2013
(Röder, Sternberg, Sunde).
3rd Annual Meeting of the Alumni Association of the MPI for Tax Law and Public Finance, Munich, November 2013 (OsterlohKonrad, Schön).
Public Finance, Munich, November 2013
(Häcker, Hellgardt, Komisarczyk, Sternberg,
Sunde).
Themenschwerpunkte und Methoden der
wissenschaftlichen Diskussion in anderen
europäischen Ländern, Professor Matthias
Ruffert, Ludwig-Maximilians-Universität
München, Munich, November 2013 (Hellgardt).
Tax Compliance in Field and Laboratory
Experiments, MPI for Tax Law and Public
Finance, Munich, November 2013 (Osterloh-Konrad).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, November
2013 (Osterloh-Konrad).
Finanzierung der GmbH, Forschungsstelle
für Notarrecht, Ludwig-Maximilians-Universität München, Munich, November 2013
(Poschenrieder, Röder).
Foundations of Economic Preferences, Ernst
Fehr, Munich Lectures in Economics, Munich, November 2013 (Sternberg).
Rechtsgeschichte – Herausforderungen der
Zukunft, Kolloquium, MPI for European Legal
History, Frankfurt, December 2013 (Schön).
United Nations, Financing for Development
Office, Seminar on Tax Treaty Administration, December 2013 (Ault).
Prinzipien der europäischen Unternehmensund Finanzmarktregulierung, Professor
Klaus J. Hopt und Professor Katharina
Pistor, CAS Ludwig-Maximilians-Universität
München, Munich, December 2013 (Hellgardt, Röder, Schön).
Quo Vadis Europe, Ifo Institute, Munich,
November 2013 (Schön).
Annual Meeting of the Wissenschaftliche
Vereinigung für Unternehmens- und Gesellschaftsrecht (VGR), Frankfurt am Main,
November 2013 (Andrianesis).
Conference on Tax Law, MPl for Tax Law and
115
115
2014
New Directions in Unjustified Enrichment:
Learning from South Africa?, Workshop,
University of Edinburgh, Edingburgh, UK,
January 2014 (Häcker).
Workshop Privatrecht, Ludwig MaxmiliansUniversität München, Munich, March 2014
(Häcker).
for Reform, MPI for Tax Law and Public
Finance, INTR, Munich, January 2014 (Oliveros Castelon, Osterloh-Konrad, Röder,
Sternberg).
IX. Tax Day, MPI for Tax Law and Public
Finance, March 2014 (Sternberg).
Conference on Understanding Tax Havens,
MPI for Tax Law and Public Finance and
Norwegian School of Economics, Munich,
January 2014 (Schön, Sternberg).
13th Annual Tax Planning Strategies: US and
Europe, International Bar Association, London, UK, April 2014 (Bienkowska).
Klausurtagung, Steuerrechtliche Fragen bei
der gemeinsamen Nutzung von Forschungsinfrastrukturen durch Hochschulen und
außeruniversitäre Forschungsorganisastionen, Schloss Ringberg, January 2014
(Heber, Schön).
Workshop Privatrecht, Ludwig MaxmiliansUniversität München, Munich, January 2014
(Osterloh-Konrad).
ZGR-Symposium, Personengesellschaftsrecht, Königstein, February 2014 (Schön).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, February
2014 (Häcker, Osterloh-Konrad).
Sir Jeremy Lever Lecture, University of Oxford, Oxford, UK, February 2014 (Häcker).
Verbesserte Kooperation zwischen Finanzverwaltung und Unternehmen – Status
Quo, Konzepte, Umsetzungschancen-, International Fiscal Association (IFA), Munich,
February 2014 (Osterloh-Konrad).
69. Sitzung des IDW Arbeitskreises “Personengesellschaften”, Institut der Wirtschaftsprüfer, Düsseldorf, February 2014 (Blezinger, Röder).
53. Münchner Steuerfachtagung, Munich,
March 2014 (Heber, Osterloh-Konrad,
Röder, Schön).
116
Lecture on the History of the College, All
Souls College, University of Oxford, Oxford,
UK, March 2014 (Häcker).
OECD Meeting, Paris, France, April 2014
(Schön).
Workshop Privatrecht, Ludwig MaxmiliansUniversität München, Munich, April 2014
(Osterloh-Konrad).
1st Annual Berlin Conference on EU and
International Tax “Latest Insights and Debates“, Conference, Queen Mary University
of London, Centre for Commercial Studies,
Berlin, April 2014 (Sternberg).
40th Anniversary of MPG-CAS Cooperation,
Präsidentendelegation, Beijing, Shanghai
(PRC), May 2014 (Schön).
65. Steuerrechtliche Jahresarbeitstagung
Unternehmen 2014, Wiesbaden, May 2014
(Balbinot, Holm, Komisarczyk, Kreutzer,
Osterloh-Konrad, Röder).
Workshop Privatrecht, Ludwig MaxmiliansUniversität München, Munich, May 2014
(Osterloh-Konrad).
PAKT-Workshop am ZEW, Centre for European Economic Research (ZEW), Mannheim,
May 2014 (Sternberg).
Summer Conference 2014: Tax Competition
and BEPS, Saïd Business School, Centre for
Business Taxation, University of Oxford, Oxford, UK, June 2014 (Meindl, Röder).
51. Berliner Steuergespräch, “Sanierung,
Insolvenzen und Steuern”, Berlin, June 2014
(Fries).
Lunchtime Talk by Professor Peregrine
Horden, All Souls College, University of Oxford, Oxford, UK, June 2014 (Häcker).
The Role of Assumption of Risk in a System
of Strict Liability: Conceptual Tangles and
Social Consequences, Lecture by Professor
Richard Epstein, Obligations Discussion
Group, University of Oxford, Oxford, UK,
June 2014 (Häcker).
Klaus-Vogel-Lecture, Wirtschaftsuniversität
Wien, Vienna, Austria, October 2014 (Bykov,
Heber, Sternberg).
Academic Symposium 2014, Saïd Business School, Centre for Business Taxation,
University of Oxford, Oxford, UK, June 2014
(Meindl, Röder).
43th Congress of the Japanese Society for
Tax Law, Nishinomiya, Japan, October 2014
(Miyamoto).
International VAT Conference 2014, Tegernsee, June 2014 (Heber).
Doktorandenseminar Institut für Steuerrecht und Institut für betriebliche Steuerlehre, Münster, July 2014 (Sternberg).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, July 2, 2014
(Häcker, Hellgardt).
Workshop Privatrecht, Ludwig-MaximiliansUniversität München, Munich, July 9, 2014
(Häcker).
European Banking Regulation, International
Conference, Center for Advanced Studies,
Munich, July 2014 (Blezinger, Hellgardt,
Schön).
Bewerbung und Berufung, Deutscher Hochschulverband, Workshop, Munich, July 2014
(Häcker, Osterloh-Konrad).
Doctorate Seminar on Comparative Tax
Law, Uppsala University, Uppsala Center
for Tax Law, Uppsala, Sweden, August 2014
(Kreutzer, Sternberg).
9th Annual GREIT Conference “International
Tax Law and New Challenges by Constitutional and Legal Pluralism”, University of
Muenster, Institute for Tax Law, Münster,
September 2014 (Heber, Sternberg).
1st Annual Journal of Law, Finance, and Accounting Conference, NYU School of Law,
New York, USA, September 2014 (Schön).
Association, Mumbai, India, October 2014
(Heber, Holm, Miyamoto, Schön).
37. Deutscher Steuerberatertag, Munich,
Conference on “The BEPS Project”, Jean
Monnet Chair of EU Law and Taxation, University of Valencia, Valencia, Spain, October
2014 (Parada).
Reforming Entity Taxation, A Boston College
Law School and Tax Analysts Conference,
Boston College Law School, Newton, MA,
USA, October 2014 (Röder).
10th Annual UF International Tax Symposium, University of Florida, Levin College of
Law, Gainville, USA, October 2014 (Röder).
Strategische Erschließung neuer Forschungsfelder, Veranstaltung im Rahmen des Paktes
für Forschung und Innovation, DFG, Berlin,
Rethinking the Global Currency System, CESLecture, Professor Kenneth Rogoff, Munich,
November 2014 (Schön, Sunde).
International Tax Audit Forum Munich –
Grenzüberschreitende Betriebsprüfungen,
ITAX Auslandsfachprüfertagung e.V., Munich, November 2014 (Osterloh-Konrad).
A Tribute to F.A. Mann, Humboldt Universität zu Berlin, Berlin, November 2014
(Schön).
Wissenschaft nach Kassenlage, MPG und
ARD-Alpha, Munich, November 2014
(Schön).
Series of PwC-WU-Seminars “Current Developments in European and International Tax
Law”, Wirtschaftsuniversität Wien, Vienna,
Austria, November 2014 (Bykov).
Russia’s Economic Policy in the Presence of
Global Turbulence, Forum, Financial University under the Government of the Russian
Federation, Russia, November 2014 (Bykov).
117
117
10th Russian Tax Forum “Tax Maneuver-2014: A View of Business and Government”, Chamber of Commerce and Industry
of the Russian Federation, Russia, November
2014 (Bykov).
Prof. Dr. Alexander Rust Inaugural Lecture,
Wirtschaftsuniversität Wien, Vienna, Austria, November 2014 (Bykov).
International Conference “The Judicial
Reform in Russia: Past, Present, and Future”,
Faculty of Law of Lomonosov Moscow State
University and Kutafin Academy of Law,
Moscow, Russia, November 2014 (Bykov).
4th Annual Meeting of the Alumni Association of the MPI for Tax Law and Public
Finance, Munich, November 2014 (Fries,
Häcker, Heber, Hellgardt, Kreutzer, Meindl,
Osterloh-Konrad, Schön, Sunde).
Conference of the Università Cattolica di
Piacenza: Immovable Property under Domestic Law, EU Law and Tax Treaties, Milan,
Italy, November 2014 (Miyamoto).
Workshop Privatrecht, Ludwig-MaxmiliansUniverstität München, Munich, November
Hochschulbesteuerung, Conference, Steuern
in Forschung und Praxis e.V., Freiburg im
Breisgau, November 2014 (Heber, Sternberg).
vbw Ausschuss für Steuer- und Finanzpolitik,
Munich, December 2014 (Schön).
Bochumer Steuerseminar für Praktiker
und Doktoranden, “Steuerliche Rahmenbedingungen für die Sanierung von Unternehmen”, Bochum, December 2014
(Fries).
Der digitale Nachlass, Tagung der Forschungsstelle für Notarrecht, LudwigMaximilians-Universität München, Munich,
November 2014 (Häcker).
Absence of Basis, Seminar on Restitution
for Unjust Enrichment, University of Oxford,
Oxford, UK, December 2014 (Häcker).
118
Workshop Privatrecht, Ludwig MaxmiliansUniverstität München, Munich, December
IIIParticipation on Committees
Meeting of the Executive Commitee and of
the Senate of the Max Planck Society, Munich, March 2012 (Schön).
2012
Board Meeting, Max Planck Foundation,
Meeting of the Scientific Advisory Board,
MPI for Research on Collective Goods, Bonn,
January 2012 (Schön).
Meeting of the Scientific Advisory Board, MPI for Social Law and Social Policy, Munich,
March 2012 (Schön).
Presidium of the Max Planck Society, Berlin,
Appointment Committee, MPI for the Study
of Societies, Munich, April 2012 (Schön).
Appointment Committee, MPI for Comparative Public Law and International Law, Hamburg, January 2012 (Hellgardt, Schön).
Presidium and Perspectives Committee of
the Max Planck Society, Munich, April 2012
(Schön).
Appointment Committee, Sciences Po, Munich, January 2012 (Schön).
Senate Committee for Research Planning of
(Schön).
Executive Board Meeting IFA, Copenhagen,
Denmark, February 2012 (Schön).
Permanent Scientific Committee (PSC) IFA,
Copenhagen, Denmark, February 2012
(Schön).
February 2012 (Schön).
Scientific Council of the Max Planck Society,
Berlin, February 2012 (Hellgardt, Schön).
HS Section Meeting of the Max Planck
Society, Berlin, February 2012 (Hellgardt,
Schön).
of Societies, February 2012 (Schön).
Medium-term Financial Planning of the
Max Planck Society, Munich, March 2012
(Schön).
Search Committee, MPI of Economics, Munich, March 2012 (Schön).
Meeting of the Scientific Advisory Board, MPI for Human Cognitive and Brain Sciences, Leipzig, March 2012 (Schön).
IT Strategic Commission, Max Planck Digital
Library, Munich, March 2012 (Schön).
Selection Committee for Supporting Members of the Max Planck Society, Munich,
President’s Commission Governance Structures of the Max Planck Society, Munich,
April 2012 (Schön).
Perspectives Committee of the Max Planck
Society, Hamburg, April 2012 (Hellgardt,
Schön).
Meeting of the Scientific Advisory Board, MPI for Social Anthropology, Halle (Saale),
Appointment Committee, MPI for the History of Science, Berlin, April 2012 (Schön).
MPI for Foreign and International Criminal
Law, Freiburg, May 2012 (Schön).
the Max Planck Society, Munich, May 2012
(Schön).
MPI for European Legal History, Frankfurt,
May 2012 (Schön).
Hessen State Ministry of Higher Education,
Research and the Arts, MPI for Empirical
Aesthetics, Wiesbaden, May 2012 (Schön).
Appointment Committee, MPI for the History of Science, Berlin, June 2012 (Schön).
119
119
63th Annual Meeting, Executive Committee,
Senate and HS Section of the Max Planck Society, Berlin, June 2012 (Hellgardt, Schön).
Meeting of the Scientific Advisory Board, MPI for the Study of Societies, Cologne,
MPI for Comparative Public Law and International Law Heidelberg, June 2012 (Schön).
Symposion MPG – CASS, Munich, November
2012 (Schön).
of Societies, Hamburg, June 2012 (Schön).
Meeting of the Executive Committee and of
the Senate of the Max Planck Society, Berlin,
Meeting of the Scientific Advisory Board, MPI for Tax Law and Public Finance, Munich,
July 2012 (all staff).
Medium-term Financial Planning of the Max
Planck Society, Munich, November 2012
(Schön).
Presidium of the Max Planck Society, Munich, July 2012 (Schön).
Concluding Meeting of the Field Committee
on Research Area No. 1 of the Max Planck
Society, Munich, November 2012 (Schön).
Meeting of the Board of Trustees, MPI for
Tax Law and Public Finance, Munich, July
2012 (all staff).
Meeting of the Board of the MPDL, Munich,
July 2012 (Hellgardt, Schön).
Core Committee, MPI of Economics, Jena,
July 2012 (Schön).
Meeting of the Scientific Advisory Board, MPI for Comparative and International Private Law, Hamburg, July 2012 (Schön).
Meeting of the Committee for the Max
Planck-Weizmann Center for integrative
Archaeology and Anthropology, Munich, July
2012 (Schön).
Society, Berlin, September 2012 (Schön).
Meeting of the Scientific Advisory Board, MPI for Biophyisical Chemistry, Göttingen,
September 2012 (Schön).
the Max Planck Society, Berlin, September
2012 (Schön).
Meeting of the Administrative Council of the
IBZ, Munich, October 2012 (Schön).
HS Section Meeting of the Max Planck Society, Berlin, October 2012 (Hellgardt, Schön).
120
December 2012 (Hellgardt, Schön).
Medium-term Financial Planning of the Max
Planck Society, Munich, December 2012
(Schön).
Meeting of the Scientific Advisory Board, Kunsthistorisches Institut in Florenz, Florence, Italy, December 2012 (Schön).
the Max Planck Society, Munich, December
2012 (Schön).
2013
German-French Initiative of the MPG – BMF,
Video Conference, March 2013 (Schön).
Finanzverfassungsreform 2019, Meeting of
the Max Planck Society, Schloss Ringberg,
MPI for the Study of Religious and Ethnic
Diversity, Göttingen, April 2013 (Schön).
Advisory Group Max Planck Society – CAS,
Munich, January 2013 (Schön).
IT-Steering-Committee of the Max Planck
Society, Munich, April 2013 (Schön).
Appointment Committee, MPI of Economics, Munich, January 2013 (Schön).
Presidium of the Max Planck Society, Munich, April 2013 (Schön).
Meeting of the Committee for the Max
Planck-Weizmann Center for integrative
Archaeology and Anthropology, Munich,
Senate Committee for Research Planning of
(Schön).
Appointment Committee, Bibliotheca Hertziana, Munich, January 2013 (Schön).
Research Board of the Ludwig-MaximiliansUniversität München, Munich, April 2013
(Schön).
IFA Executive Board (EB), The Hague, Netherlands, January 2013 (Schön).
Standorttreffen München of the Max Planck
February 2013 (Hellgardt, Schön).
Appointment Committee, MPI of Economics, Munich, April 2013 (Schön).
IFA Permanent Scientific Committee (PSC),
The Hague, Netherlands, February 2013
(Schön).
Society, Munich, April 2013 (Hellgardt,
Schön).
IStR Editorial Board, Munich, February 2013
(Schön).
Meeting of the Board of Trustees, Friends,
and Supporters of the Bavarian State Library, Munich, May 2013 (Schön).
HS Section Meeting of the Max Planck
Society, Berlin, February 2013 (Hellgardt,
Schön).
Appointment Committee, MPI for Demographic Research, Berlin, May 2013 (Schön).
Presidium DFG and Max Planck Society,
Berlin, February 2013 (Schön).
Discussion “Steuergestaltungen Internationaler Konzerne und BEPS-Initiative der
OECD”, Federal Chancellery, Berlin, June
2013 (Schön).
Scientific Council of the Max Planck Society,
Berlin, February 2013 (Hellgardt, Schön).
Munich, June 2013 (Schön).
Scientific Advisory Board of the Deutsche
Steuerjuristische Gesellschaft (DStJG), Munich, March 2013 (Schön).
Senate, and HS Section Meeting of the Max
Planck Society, Potsdam, June 2013 (Hellgardt, Schön).
Meeting of the Executive Commitee and of
the Senate of the Max Planck Society, Munich, March 2013 (Schön).
Reception of a Mongolian Delegation, Max
Planck Society, Munich, June 2013 (Schön).
Appointment Committee, Bibliotheca Hertziana, Munich, June 2013 (Schön).
121
121
of Societies, Cologne, June 2013 (Hellgardt,
Schön).
Appointment Committee, MPI Luxembourg
for International, European and Regulatory Procedural Law, Hamburg, June 2013
(Schön).
Appointment Committee, MPI of Economics, Berlin, June 2013 (Schön).
Joint Selection Committee for Research
Group Leaders, Maxpo, Munich, June 2013
(Schön).
Appointment Committee, MPI of Economics, Bonn, October 2013 (Schön).
October 2013 (Hellgardt, Schön).
Shareholders’ Meeting, Max Planck Foundation for International Peace and the Rule of
Law, Munich, October 2013 (Schön).
Discussion on Tax Policy, Federal Ministry of
Finance, Berlin, October 2013 (Schön).
July 2013 (Hellgardt, Schön).
Munich, October 2013 (Schön).
2013 (Manta, Schön, Singer, Wanger).
the Max Planck Society, Munich, October
2013 (Schön).
Presidium of the Max Planck Society, Munich, July 2013 (Schön).
Executive Committee, MPI Luxembourg for
International, European and Regulatory
Procedural Law, Luxembourg, October 2013
(Schön).
Reform Commission, Bayerische Akademie
der Wissenschaften, Munich, July 2013
(Schön).
Appointment Committee, MPI for Demographic Research, Munich, August 2013
(Schön).
Scientific Advisory Board, and General Assembly of the Deutsche Steuerjuristische
Gesellschaft (DStJG), Berlin, September
2013 (Schön).
Appointment Committee, Bibliotheca Hertziana, Munich, September 2013 (Schön).
the Max Planck Society, Munich, September
2013 (Schön).
“Tag mit Wissenschaft” of the Max Planck
Society, Schloss Ringberg, Tegernsee, September 2013 (Schön).
Meeting of the Board of Trustees, Friends
and Supporters of the Bavarian State Library, Munich, September 2013 (Schön).
der Wissenschaften, Munich, September
2013 (Schön).
122
Society, Bonn, September 2013 (Schön).
HS Section Meeting of the Max Planck Society, Berlin, October 2013 (Hellgardt, Schön).
Appointment Commitee, MPI for the Study
of Societes, Berlin, October 2013 (Hellgardt).
Appointment Committee, MPI for Demographic Research, Berlin, November 2013
(Schön).
Meeting of the Working Group “Organisationsstrukturen”, Bayerische Akademie der
Wissenschaften, Munich, November 2013
(Schön).
MPI for Evolutionary Anthropology, Leipzig,
Meeting of the Board of Trustees, Hertie
School of Governance, Berlin, November
2013 (Schön).
Project Meeting “History of the Max Planck
Society”, Berlin, November 2013 (Schön).
Presidium and Excecutive Committee of the
Max Planck Society, Berlin, November 2013
(Schön).
Selection Committee for Supporting Members of the Max Planck Society, Berlin,
2014
MPI for Research on Collective Goods, Berlin, January 2014 (Schön).
4th Max Planck Center Meeting, Munich,
Celebration on the Occasion of Professor
Wolfrum’s Farewell, and the Official Introduction of Professor Peters, MPI for Comparative Public Law and International Law,
Heidelberg, November 2013 (Schön).
Appointment Committee, Bibliotheca Hertziana, Munich, January 2014 (Schön).
MPI for Comparative Public Law and International Law, Heidelberg, November 2013
(Schön).
Presidium of the Max Planck Society, Munich, January 2014 (Schön).
of Societes, Berlin, November 2013 (Hellgardt, Schön).
Appointment Committee, MPI for European
Legal History, Frankfurt, December 2013
(Schön).
MPI for Psycholinguistics, Nijmegen, Netherlands, December 2013 (Schön).
der Wissenschaften, Munich, December
2013 (Schön).
International Tax Group Meeting, Oxford
University Centre for Business Taxation,
Saïd Business School, Oxford, UK, December
2013 (Schön).
Search Committee, MPI Jena, Bonn, January
2014 (Schön).
Taxation of Research Cooperation, Max
Planck Society, Schloss Ringberg, January
2014 (Heber, Schön).
Joint Selection Committee for Max Planck
Research Group Leaders, Munich, February
2014 (Schön).
IFA Permanent Scientific Committee,
Prague, Czech Republic, February 2014
(Schön).
IStR Editorial Board Meeting, Munich, February 2014 (Schön).
MPI for Human Cognitive and Brain Sciences, Leipzig, February 2014 (Schön).
Meeting PAAR, Max Planck Society, Munich,
HS Section Meeting, and Scientific Council
of the Max Planck Society, Berlin, February
2014 (Schön).
IT Steering Group, Munich, February 2014
(Schön).
IFA Presidium, Executive Committee Meeting, General Meeting, Munich, March 2014
(Schön).
123
123
Meeting of the Executive Committee, and
of the Senate of the Max Planck Society,
Audit Committee of the Max Planck Society,
MPI for the Study of Religious and Ethnic
Diversity, Göttingen, March 2014 (Schön).
MPI for Social Anthropology, Halle, April
2014 (Schön).
Appointment Committee, Ludwig-Maximilians-Universität München, Succession to
Moris Lehner, Munich, April 2014 (Schön).
ZHR Editorial Board Meeting, Frankfurt,
Appointment Committees of the HS Section
of the MPG, Bonn, April 2014 (Schön).
Appointment Committee, Archives of the
Max Planck Society, Munich, April 2014
(Schön).
June 2014 (Schön).
Senate and HS Section Meeting of the Max
Planck Society, Munich, June 2014 (Hellgardt, Schön).
Meeting of the Board of Trustees, ifo Institute, Munich, June 2014 (Schön).
International Tax Group Meeting, Oxford
University Center for Business Taxation,
Saïd Business School, Oxford, UK, June 2014
(Schön).
Annual Meeting of the Deutsche Forschungsgemeinschaft (DFG), Frankfurt, July
2014 (Schön).
2014 (Hornung, Lang, Konrad, Manta,
Röder, Schön, Wanger).
Project Meeting “History of the MPG”, Berlin, August 2014 (Schön).
Appointment Committee, MPI for European
Legal History, Munich, April 2014 (Schön).
HS Section Meeting of the Max Planck Society, Berlin, October 2014 (Schön).
Perspectives Committee of the HS Section, Max Planck Society, Bonn, April 2014
(Schön).
Society, Munich, October 2014 (Schön).
Preparation of the Meeting of the Senate of
the DFG, Berlin, November 2014 (Schön).
MPI for Human Development, Berlin, May
2014 (Schön).
Appointment Committee, Ludwig-Maximilians-Universität München, Munich, May
2014 (Schön).
MPI for the Study of Societies, Cologne, May
2014 (Schön).
June (Hellgardt, Schön).
124
Meeting of the Max Planck Legal Studies
Network, Munich, June 2014 (Schön).
Committee Meeting, “History of the Max
Planck Society”, Berlin, November 2014
(Schön).
Meeting of the Board of Trustees, Hertie
School of Governance, Berlin, November
2014 (Schön).
Audit Committee of the Max Planck Society,
Berlin, November 2014 (Schön).
der Wissenschaften, Munich, November
2014 (Schön).
Network Meeting of the Alexander von
Humboldt Foundation, Julius-Maximilian
University of Würzburg, Würzburg, November 2014 (Miyamoto).
Meeting of the Board of Trustees, Friends
and Supporters of the Bavarian State Library,
Munich, December 2014 (Schön).
Research Policy Council of the Max Planck
Society, Berlin, December 2014 (Schön).
Senate, Presidium and General Committee
of the DFG, Bonn, December 2014 (Schön).
Meeting of the Board of Trustees, IBFD,
Amsterdam, Netherlands, December 2014
(Schön).
125
125
126 Department of Public Economics
AResearch in Public Economics
This activity report describes the developments in, and the scientific achievements of the Public Economics Department in the three years from 2012 to
2014. A first part provides information
on the human resources and on the communication activities. This includes brief
biographies of the members of the group
and the Department’s internal scientific
meetings, workshops, and conference
activities. The following parts report the
main research output in the areas of
“Understanding Taxation and Tax Compliance”, “International Public Finance”,
and “Political Economy of Distribution
and Conflict”.
The report is followed by a listing of
publications, presentations, committee
work and other documented scientific
activities. It also includes an overview of
the guest lectures and some highlights
from the media coverage. Most research
projects within economics take several –
often many – years between the first idea
and eventual publication. This makes it
difficult to assign each and every project
precisely to one audit period. The mobility of young researchers generates a
further problem: Some researchers bring
projects with them when they arrive at
our Institute while others start projects
at the Institute but then continue or
complete these projects elsewhere. For
instance, Ph.D. students typically pursue
research at the Institute that is then published after they have left the Institute.
The report in section A focusses on research in projects for which it holds that at
least a share of this work was conducted
by researchers while their main affiliation
was the Max Planck Institute. The report
in section B takes stock of all publications
that appear, and paper acceptances that
happened, in the reporting period and
while the Max Planck Institute for Tax Law
and Public Finance was (at least one of)
the formal affiliation(s) of the respective
researcher. This implies that papers accepted but not published in one reporting
period will be reported as forthcoming,
and will also be included as published
in the next activity report. Though such
papers are reported twice, they are only
listed to give as accurate a picture as possible of what happened in a given reporting period. The report also includes publications of the Ph.D. theses of doctoral
students or papers from their theses (as
far as these can be traced) and of work
of senior researchers if the origin of this
research can clearly be traced to their period of employment at the Institute, even
if the researchers have already left the
Institute. The reporting of other activities
of researchers is easier: activities other
than publications are reported only as far
as these activities were pursued while the
persons’ main affiliation was the MPI.
127
I
Who we are
The Department of Public Economics has
a human resource structure which is typical for units in the humanities section of
the Max Planck Society. The Department
consists of a group of Ph.D. students, a
group of senior research fellows, and a
director. Most of the researchers hold
multiple-year non-tenured positions.
These positions allow researchers to gain
the qualification for more senior positions, in most cases positions outside the
Max Planck Society.
Country composition
in December 2012, December 2013, and December 2014
Phillipines
The Netherlands
Egypt
China
Germany
2012
2013
2014
Figure 1 shows the composition of the
nationalities of the Ph.D. students and senior research fellows working at the Department in 2012 to 2014.
The fluctuation among researchers is
substantial. On average, about 20 to 30
per cent of the members of the group
leave the Institute and must be replaced
by young entrants within a period of two
years. This requires that the Department
pursues a steadily active policy of recruiting both at the Ph.D. student level and at
the level of senior research fellows.
1. Ph.D. Students
In the reporting period the number of
Ph.D. students simultaneously in residence was about eight.
The Department advertises the Ph.D.
program widely in each year both on
the internet and by sending posters
with a call for applications to more than
500 economics Departments around
the world. Students admitted typically
applied directly to the Institute or via
the internet application platform of the
Munich Graduate School of Economics
(MGSE). The students in this reporting
period hold degrees from diverse places,
including the London School of Economics and Political Science (London/UK),
Harvard University (Cambridge/USA),
University of Oxford (Oxford/UK), University of the Philippines Manila (Manila/
Philippines), Universitat Autònoma de
Barcelona (Barcelona/Spain), Technische
Universität München, Ludwig-Maximilians-Universität München, University of
Hohenheim, University of Cologne, and
University of Mannheim.
Ph.D. students at the Department also
enroll with a university. Their respective
Ph.D. committee is at the university and
the Ph.D. granted is a degree awarded by
the respective university. In the reporting
period some students in the Department
were enrolled at the Freie Universität
Berlin in the Ph.D. programme of the
Berlin Doctoral Program in Economics
and Management Science (BDPEMS),
a majority of students were enrolled
at the Ludwig-Maximilians-Universität
München in Munich (LMU) at the Munich
Graduate School of Economics (MGSE). A
contract between the LMU and the Max
Planck Institute establishes this collaboration between the two institutions in
more formal terms.
Admission and participation in these doctoral programmes imply that students
take part in their respective structured
Ph.D. programmes and successfully complete the mandatory coursework that is
part of the Ph.D. programme. Depending
on the education background of students
at the time of admission and the graduate courses they have previously taken
at other institutions, completion of this
programme takes students about one
year on average before they start fulltime work on their thesis research.
The director of the unit holds an affiliation as an honorary professor at both
LMU in Munich and the Freie Universität
Berlin. This makes him eligible as a chair
of Ph.D. committees for the students
who are supervised in the Public Economics group at these two universities.
He acts as the main thesis advisor for all
students admitted to the Department at
the Institute.
As is usual in Germany, not all doctoral
students aim at a career in academia.
Some do, others aim at positions in supranational institutions and NGOs, while
some aim to work for the public sector or
the private sector.

May Elsayyad took up a position at Allianz SE in Munich. She has published
several papers in very good or top
field journals. Her preference was not
to follow an academic career.

Rhea Molato handed in her thesis on
“Differences in the Public Sector: Essays on Secession Threats and Wage
Differentials” in autumn 2014. The
reports on her thesis are positive. She
will defend her thesis on 6 May 2015.
She left the Institute in autumn 2014
and took up a position as a postdoctoral researcher at the HealthEconLab
of the University of the Philippines
Manila, School of Economics.

Phillip Meyer-Brauns handed in his
thesis in autumn 2014 and defended
at the Freie Universität Berlin on 26
January 2015. The grade “summa
cum laude” was granted. He takes a
position in Austin, Texas, in the research department of “Dimensional
Fund Advisors“, a firm for investment
solutions.

Sabine Aresin is about to complete her
Ph.D. thesis and has taken a research
position at the Ludwig-MaximiliansUniversität München.

Thomas Daske is also close to completion and has accepted a teaching and
129
research position at the Technische
Universität München.


Anne-Kathrin Bronsert left the Institute to work as an analyst for “Connect Energy Economics“, a consultancy for decision makers in energy
policy and energy economics based in
Berlin. Her Ph.D. thesis is likely to be
completed in autumn 2015.
Michael Hilmer handed in his thesis
in autumn 2014 and will defend on 6
May 2015 at the Ludwig-MaximiliansUniversität München. The thesis
re-ports are excellent. He has taken
a position as an assistant to Horst
Seehofer, the current Prime Minister
of Bavaria and party leader of the governing Christian Social Union.
Ph.D. Students
Completed and expected completion
2010
Sabine Arensin
2011
2012
2013
2014
Essays in Public Finance
Kai Brückerhoff
May Elsayyad
2016
Topics in Public Finance
Anne-Kathrin Bronsert
Thomas Daske
2015
Fighting Tax Havens and Climate Change
Luisa Herbst
Essays on Contest Experiments
Michael Hilmer
Taxing Manager’s Bonuses: Essays on the Implications of Bonus Taxation
Harald Lang
Philipp Meyer-Brauns
Essays in Public and Corporate Finance
Rhea Molato
Differences in Public Sector: Essays on Secession Threats and Wage Differentials
Sven-Arne Simon
Tim Stolper
Figure 2 provides an overview of the composition of the group of Ph.D. students in the
audit period, who entered when, and who left when. The figure also lists the date and
topic of the Ph.D.´s that were successfully granted in this period, and the expected completion for the Ph.D. students who are currently in the programme.
Ph.D. students of the unit are strongly
encouraged to submit their research output to national and international conferences and to academic journals. This has
led to a large number of conference presentations by young scholars at international conferences such as the meetings
of the European Economic Association,
the Association for the Public Economic
Theory, the Royal Economic Society, the
German Economic Association, and conferences of the International Institute of
Public Finance.
Total Number of Presentations at Conferences
60
45
30
15
0
Ph.D.
2012
Post-Doc
Ph.D.
2013
Post-Doc
Ph.D.
2014
Post-Doc
Refereed external
conferences
1
13
9
10
10
19
Invited seminars and
external workshops
4
16
7
21
7
25
Internal brown bags,
seminars and workshops
12
10
13
15
12
10
Average Number of Presentations per Researcher
12
9
6
3
0
Ph.D.
2012
Post-Doc
Ph.D.
2013
Post-Doc
Ph.D.
2014
Post-Doc
Refereed external
conferences
0.12
2.89
0.97
2.22
1.04
3.74
Invited seminars and
external workshops
0.47
3.56
0.76
4.67
0.73
4.92
Internal brown bags,
seminars and workshops
1.41
2.22
1.41
3.33
1.25
1.97
Figure 3 and 4: Overall frequencies of active conference participation of Ph.D. students
at these events in different years. You can find a full list of the conferences attended in
the reporting period on page 227. These conferences provide the Ph.D. students with
an opportunity to meet and make contact with other young scholars, disseminate their
work and learn more about academic life in general.
131
Other activities that were supported
and encouraged for similar purposes are
student research visits, participation in
Research Visits
summer schools, and internships at international organisations.
Internships

Sabine Aresin
Simon Fraser University,
Burnaby, Canada |
September – December 2013

European Commission, Brussels,
Belgium |
October – December 2014

Freie Universität Berlin |
December 2013


Rhea Molato
University of the Philippines,
Manila, Philippines |
January 2013
Harald Lang
European Investment Bank,
Luxembourg |
November 2013 – January 2014
April – May 2014

Tim Stolper
University of Copenhagen,
Denmark |
September – December 2014
Summer Schools

Harald Lang
Barcelona GSE Summer School
2013, Spain |
July 2013

Tim Stolper
IIPF Doctoral School on International Corporate Taxation,
Oxford, UK |
September 2014
Sabine Aresin
Sabine Aresin graduated from the Ludwig-Maximilians-Universtät München. She joined the group in October 2010. Her work is on international climate policy. A focus of her work is on the Clean Development
Mechanism (CDM). This regulation is an important
element of the Kyoto Protocol. She plans to complete
her Ph.D. in 2015.
Anne-Kathrin Bronsert is a graduate from the University of Cologne. She joined the group in October 2011.
She works on different aspects of conspicuous consumption, particularly in relation to taxation and tax
enforcement. She took a position at Connect Energy
Economics in Berlin in January 2015.
Kai Brückerhoff completed his BA (Hons) at Oxford
(Trinity College) in 2008, spent four years at Goldman
Sachs and then graduated from the Harvard Kennedy
School of Government. He joined the group in October 2014. His general research interest lies in financial
market regulation.
Kai Brückerhoff
Thomas Daske joined in October 2010. He is a mathematician by training and graduated from the Technische Universität München. He works on problems
of collective action with subjects who have otherregarding preferences. He plans to complete his Ph.D.
in 2015 and moves to a researcher position at the
Technische Universität München in April 2015.
Thomas Daske
133
May Elsayyad graduated from the University of Cologne before entering into the MGSE as a Ph.D. student. She joined Max Planck in 2010. She successfully
completed and defended her thesis “Fighting Tax Havens and Climate Change” in 2012. She has taken a
position at the Allianz SE.
May Elsayyad
Luisa Herbst graduated from the University of Mannheim. She joined the group in October 2010. She has
a full-time position at the Sonderforschungsbereich
Transregio 15, funded by the German Research Foundation (DFG). One major focus of Luisa Herbst’s work
is the formation of alliances in the context of redistributive conflict.
Luisa Herbst
Michael Hilmer
Michael Hilmer graduated from the Ludwig-Maximilians-Universität München before joining the Institute
in October 2010. He handed in his Ph.D. thesis in autumn 2014. He studies the incentive effects and the
incidence effects of the tax treatment of bonus payments to managers in a general equilibrium model
with limited liability on the side of managers and
moral hazard.
Harald Lang studied at UC Berkeley, the University of
Sydney, and graduated from the Ludwig-MaximiliansUniversität München in 2012. He joined Max Planck
in October 2011. His research is on the information
aspects of interpersonal comparisons, motivated by
what Hirschman refers to as “the tunnel effect”.
Harald Lang
Philipp Meyer-Brauns graduated from the London
School of Economics and Political Science. He joined
the group in October 2010 and completed his Ph.D.
thesis in autumn 2014. His research focusses on theoretical aspects of corporate tax evasion and the title of
his thesis is “Essays in Public and Corporate Finance”.
He completed the oral defense in January 2015 and
started working at Dimensional Fund Advisors in Austin as a Research Associate in 2015.
Rhea Molato, was a graduate from the University of
the Philippines before she joined the Institute in October 2010. She handed in her thesis in autumn 2014
and will defend her thesis entitled “On Differences in
the Public Sector: Essays on Secession Threats and
Wage Differentials” in spring 2015.
Rhea Molato
Sven Arne Simon studied in Mannheim and Copenhagen and completed his Master of Science in Economics in Mannheim in 2014. He joined Max Planck in
October 2014. His research interest is in theoretical
and experimental public finance. He also takes administrative responsibility for the Max Planck Experimental Laboratory econlab.
Sven Arne Simon
Tim Stolper completed his MSc in Finance and Economics (with distinction) at the London School of Economics before he joined Max Planck in October 2012.
He recently spent several months as a guest researcher at the University of Copenhagen. His research is on
understanding tax havens.
Tim Stolper
135
2.Senior Research Fellows
In the reporting period the group of senior research fellows consisted of between
four to six young researchers with a Ph.D.
The senior research fellows typically join
the Institute at the stage when their
Ph.D. thesis is about to be completed or
has just been completed. The contract
is typically for a period of 3+3 years and
positions are non-tenured. This design
and the characterisation of the positions
are prototypical for research positions at
many Max Planck Institutes. Senior research fellows can freely pursue broadly
defined basic research within the programme. Collaboration on major projects of the Department is very welcome
and encouraged. A large share of the
members of the Department participate
in some of these joint projects, another
share pursues own research within the
research area of the Department independently and often with collaborators
from outside the Institute.
The resources for academic travel to conferences, for exchange research stays, the
research money for running laboratory
experiments, for hiring student research
assistants, for IT hardware and software
and for other standard research tools
are available and pooled. Researchers
can also draw on the library resources of
the Institute and the Max Planck Digital
Library and, since 2015, can use a newly
established experimental laboratory that
is a joint venture with the Max Planck
Institute for Innovation and Competition.
The senior research fellow positions
come without a tenure perspective. It is
not surprising that the senior research
fellows move on to more senior, tenured positions when interesting options
emerge. This often happens after only
a few years. As a policy that is common
in the Max Planck Society, the Institute
does not make counteroffers to senior
research fellows if they receive an offer
for a senior position as a professor. This,
together with the high productivity and
competitiveness of the group of senior
research fellows, causes considerable
mobility in this group.
In the reporting period Salmai Qari left
for a professorship at the Berlin School
of Economics and Law, Changxia Ke left
for an academic position in China and
moved on to Australia not much later.
Fangfang Tan took up a position first at
the University of California at Santa Cruz
and later in the research department of
Facebook. Nadja Dwenger is on her way
to a professorship. Former senior research fellows often keep close links with
the Institute.
Senior research fellows travel substantially. They participate in a large number
of conferences, are frequently invited
as visiting scholars and to departmental
seminars or workshops. This is evident
from figures 3 and 4 on page 131 and
from the further information in parts B
and C of this report.
Research Visits

Nadja Dwenger
University of California, Berkeley,
USA | August – December 2012
NHH, Bergen, Norway | May 2014
University of California, Berkeley,
USA | November – December 2014
Harvard University, Cambridge, USA |
since January 2015

Florian Morath
Columbia University in the City of
New York, New York, USA | October
2011 – June 2012
April 2013

University of Zurich, Switzerland |
October 2012
George Mason University, Fairfax,
USA | November – December 2012
Carnegie Mellon University, Pittsburgh, USA | March 2013
University of California, Santa Cruz,
USA | April 2013
Fanfang Tan
Carnegie Mellon University, Pittsburgh, USA | April 2012
Nadja Dwenger
Nadja Dwenger received her Ph.D. at the Freie Universität Berlin in February 2010 for her work on
“Corporate Income Taxation and Firms’ Investment
and Financing Decisions”. She joined Max Planck
in 2010. She has been a member of the committee
“Public Economics” of the German Federal Ministry of
Finance since 2010. Her research interest is on empirical public economics and applied microeconometrics,
in particular in the areas of tax compliance and tax
enforcement, corporate taxation and the economics
of education. She was awarded the Schmölders prize
2014 for her work on tax compliance.
137
Aart Gerritsen
Erik Hornung
Changxia Ke
Aart Gerritsen has a Bachelor’s degree from Utrecht
University and a Master’s degree from the University of
Groningen, both in Economics and cum laude. Before
starting his Ph.D., he worked for a year as an economic
researcher at McKinsey & Company. He completed his
Ph.D. at the Erasmus University Rotterdam in February
2014, cum laude. The title of his dissertation is “Essays
in Optimal Government Policy”, part of which has been
awarded the 2011 IIPF Young Economist Award. In November 2013 he joined the MPI as a senior research
fellow.
Erik Hornung graduated from the University of Stuttgart. He worked in the Department of Human Capital
and Innovation at the ifo-Institute and as a tax advisor
in the Transfer Pricing Group of Deloitte and Touche
GmbH before joining the MPI in 2013 as a senior research fellow. He completed his Ph.D. at the LudwigMaximilians-Universität München in May 2012 with
summa cum laude. The topic of his thesis was “Human
Capital, Technology Diffusion, and Economic Growth
– Evidence from Prussian Census Data”. He was a research fellow at the University of Warwick in 2012.
Changxia Ke obtained her Ph.D. degree in Economics
from the University of Adelaide in 2010. She joined the
MPI in December 2009 and was working at the Sonderforschungsbereich TR-15 on “Governance and the Efficiency of Economic Systems” until July 2012. She is
currently a postdoctoral research fellow at the School
of Economics and Finance, Queensland University of
Technology. Her research interests are focussed on
experimental and behavioural economics, in particular,
the applications of microeconomic theory in areas of
industrial organisation and political economy.
Florian Morath
Fangfang Tan
Salmai Qari
Florian Morath graduated from the University of
Karlsruhe. He worked at the Sonderforschungsbereich
TR-15 on “Governance and the Efficiency of Economic
Systems” at the Freie Universität Berlin and at the
WZB Berlin Social Science Center before joining the
MPI in 2009 as a senior research fellow. He completed
his Ph.D. at the Freie Universität Berlin in January
2010. The topic of his thesis was “On Knowledge and
Ignorance – the Strategic Role of Information in Conflicts”. He was a visiting fellow at Columbia University
in 2011–2012.
Fangfang Tan, prior to joining the Max Planck Institute, studied at Zhejiang University for her Bachelor’s
degree in China (top 3 per cent in her cohort) and
Tilburg University in the Netherlands for her Master’s
degree (cum laude). In January 2012 she attained her
Ph.D. in Economics at Tilburg University with a thesis
titled “Behavioral Heterogeneity in Economic Institutions”. While working at the MPI, she visited several
universities for research purposes including Carnegie
Mellon University, University of Zurich, George Mason
University, and the University of California Santa Cruz.
Salmai Qari graduated from the Freie Universität Berlin where he also completed his Ph.D. with summa
cum laude. The title of the thesis is “Essays on Family
Economics and Social Policy”. Prior to joining the MPI
in 2009 as a senior research fellow, he was a research
fellow at the WZB Berlin Social Science Center. Before
joining the WZB, he worked in the area of statistical
and econometric modelling of risk. In April 2014 he
became a professor of Econometrics at the Berlin
School of Economics and Law.
139
Senior Research Fellows
2009
2010
2011
2012
2013
2014
2015
Nadja Dwenger
Aart Gerritsen
Erik Hornung
Changxia Ke
Florian Morath
Salmai Qari
Fangfang Tan
Changxia Ke
Postdoctoral Research Fellow at the Queensland University of Technology, Brisbane, Australia
Salmai Qari
Professor of Econometrics at the Berlin School of Economics and Law
Fangfang Tan
Researcher at Facebook
Figure 5 provides an overview of the composition of the group of senior research fellows in the reporting period, who entered when, and who left when and to where.
IIResearch Conferences and
Internal Workshops
The Department continued its communication strategy with a large number
of research conferences and internal or
semi-internal workshops. The research
conferences in the reporting period are
listed on the following pages:
Empirical Methods in Public Finance
Organisers: Nadja Dwenger, May Elsayyad, Salmai Qari
Location: MPI Munich
Date: 15–16 March 2012
On 15–16 March 2012, the MPI for Tax
Law and Public Finance invited outstanding young researchers from all over the
world to learn from each other about
their cutting-edge empirical work on
public finance. About 20 top young
economists accepted the invitation.
Nine speakers presented work in progress in the field of microeconometrics
and public finance, including Greogori
Baetschmann (University of Zurich, Switzerland), Valerio Merlo (ETH Zurich,
Switzerland), Li Liu (University of Oxford,
UK), Peter Egger (ETH Zurich, Switzer-
land), Anastasia Semykina (Florida State
University, USA), Martin Ljunge (University of Copenhagen, Denmark and Stockholm School of Economics, Sweden) and
Day Manoli (University of California, Los
Angeles, USA).
Taxation and Redistribution
Organisers: Changxia Ke, Kai A. Konrad,
Fanfang Tan
Date: 6 June 2012
The workshop on taxation and redistribution focussed on the most recent empirical work and on controlled laboratory experiments that aimed at a better understanding of the social and redistributional
motivations of individuals. It brought together a strong group of researchers from
experimental economics that consider
the role of taxation for redistribution and
related problems in public finance, who
mutually exchanged information regarding their most current research. Leading
experimentalists who presented at the
workshop were Ernesto Reuben (Columbia University, USA), Marie-Claire Villeval
(Université de Lyon, France), Jean-Robert
Tyran (University of Vienna, Austria), Jens
Grosser (Florida State University, USA),
Arno Riedl (Maastricht University, Netherlands), Karl Ove Moene (University of
Oslo, Norway) and Lise Vesterlund (University of Pittsburgh, USA).
Munich-Tokyo Conference on
Federal Public Economics
Organisers: Toshihiro Ihori (University of
Tokyo, Japan), Kai A. Konrad
Date: 13 September 2012
This workshop was inspired by several
highly productive meetings of public
finance economists from the University
of California, Irvine and the University
of Tokyo. Invitees were public finance
economists from the University of Tokyo
and other universities in the greater Tokyo region, with the aim of establishing
141
scientific contact and exchange between
researchers from the Max Planck Institute and leading public finance economists from Japan. Presenters include Junichi Itaya (Hokkaido University, Japan),
Amihai Glazer (University of California,
Irvine, USA), Kai A. Konrad, Hiroki Kondo
(Sophia University, Japan), Takashi Sato
(Shimonoseki City University, Japan) and
Wolfgang Schön.
Public Economics. Speakers at this event
were, among others, Marius Brühlhart
(Université de Lausanne, Switzerland),
Marie-Laure Breuillé (Institut National
de la Recherche Agronomique, France),
Justin Valasek (Social Science Research
Center Berlin – WZB), Enrico Spolaore
(Tufts University, USA), Gerald Schneider
(Universität Konstanz), Thomas König
The End of Federalism?
Organisers: Benny Geys (WZB), Kai A.
Konrad, Ronnie Schöb (Freie Universität
Berlin)
Location: WZB Berlin Social Science
Center, Berlin
Date: 29–30 October 2012
This international conference marked
the end of a WGL-funded project on federalism which also involved researchers
from TU Dresden and the University of
Mannheim. It took stock of the achievements of PhD students who were funded
for several years as part of this project,
and of cutting-edge research by a group
of more senior researchers in the field.
The project was initiated by Kai A. Konrad
when he was still at the WZB Berlin Social Science Center. Researchers from the
Zentrum für Europäische Wirtschaftsforschung (ZEW) in Mannheim, the ifoInstitute Dresden, and from the Max
Planck Institute joined forces to research
fiscal federalism and advise a small group
of Ph.D. students who were funded by
the programme. The event closed with
the conclusion that federalism, and in
particular the political economy of it, will
remain high on the research agenda in
(University of Mannheim), Eckhard
Janeba (University of Mannheim), Thiess
Büttner (Friedrich-Alexander-Universität
Erlangen-Nürnberg), Sebastian Kessing
(Universität Siegen) and James M. Snyder Jr. (Harvard University, USA).
Shaping the Fiscal Institutions
of Europe
Organisers: International policy conference, jointly organised by Kai A. Konrad
and the Federal Ministry of Finance,
Christian Kastrop und Ludger Schuknecht
Location: Federal Ministry of Finance,
Berlin
Date: 21 November 2012
The European public debt crisis within the
Eurozone remains one of the challenging
problems of this decade. Most economic
researchers agree that the constitution
of current institutions of the Eurozone is
and Centre d’Economie de la Sorbonne,
France), Changxia Ke (MPI for Tax Law
and Public Finance and Lingnan University
College at Sun Yat-Sen University, China),
Dana Sisak (Erasmus University Rotterdam, Netherlands), Qian Fu (National University of Singapore, Singapore), Fangfang
Tan, Jacob Goeree (University of Zurich,
at the heart of the problem. Researchers advocate various reform measures.
Should Europe adapt a centralised fiscal
model or rather follow a decentralised
approach? At the conference “Shaping
the Fiscal Institutions of Europe”, partially
funded by the German Bundestag, on 21
November in Berlin, it became clear that
there is no common vision for the Euro
Area as yet. Among the speakers were
Wolfgang Schäuble (Federal Minister
of Finance, Germany), Charles Wyplosz
(Graduate Institute Geneva, Switzerland),
Jörg Rocholl (President European School
of Management and Technology Berlin),
Thomas Philippon (New York University,
USA, former advisor to the French Minister of Finance) and Vitor Gaspar (former
Minister of Finance of Portugal).
Contests: Experiments and Theory
Organisers: Kai A. Konrad, Fangfang Tan
Date: 9–10 January 2013
This workshop featured cutting edge
research on contests – a particularly salient type of conflict game – by theorists
and empirical economists. There were
stimulating presentations by Loukas
Balafoutas (University of Innsbruck, Austria), Mehrdad Vahabi (Université Paris 8
Switzerland), Jordi Brands (Universitat
Autònoma de Barcelona, Spain), Joseph
Tao-Yi Wang (National Taiwan University,
Taiwan) and Florian Morath. Henrik Orzen
(University of Mannheim), Martin Sefton
(University of Nottingham, UK) and Luca
Stanca (University of Milano-Bicocca,
Italy) demonstrated the dynamics of this
research area.
Advances on the Political Economy of
Conflict and Redistribution II
Organisers: Thomas Cusack, (WZB), Kai
A. Konrad, Karl Ove Moene (University
of Oslo, Norway)
Location: WZB Berlin Social Science
Center, Berlin
Date: 28–29 October 2013
This international conference was a joint
initiative of the MPI for Tax Law and Public Finance, the WZB Berlin Social Science
143
Center and the Norwegian Centre of Excellence on Equality, Social Organisation,
and Performance at the University of
Oslo. It was a platform for the exchange
of ideas and for the presentation of the
most research from economists and political scientists aiming at a better understanding of the causes and consequences
of redistributional conflict. Speakers at
the workshop were Pablo Beramendi
(Duke University, USA), Joan Esteban
(Barcelona Graduate School of Economics and Spanish National Research Council – CSIC, Spain), Dan Kovenock (Chapman University, USA), Erik O. Sørensen
(NHH Norwegian School of Economics
and Business Administration (NHH) and
University of Oslo, Norway), Debraj Ray
(New York University, USA), Marta Reynal-Querol (Barcelona Graduate School
of Economics and Universitat Pompeu
Fabra, Spain), Branko Milanovic (World
Bank), Gerald Schneider (Universität Konstanz), Rajiv Sethi (Columbia University,
USA), Stergios Skaperdas (University of
California, Irvine, USA), Halvor Mehlum
(University of Oslo, Norway) and Andrea
Mattozzi (European University Institute,
Italy).
Tax Compliance in Field and
Laboratory Experiments
Organisers: Kai A. Konrad, Nadja Dwenger
Date: 4–5 November 2013
The international research workshop attracted leading experts and researchers
conducting controlled laboratory and
field experiments on tax compliance. It
was also a forum for the presentation of
recent work emerging from the research
projects inside the Department. Presenters at the workshop were Henrik Jacobsen Kleven (London School of Economics,
UK), Benno Torgler (Queensland University of Technology, Australia), Johannes
Rincke (Friedrich-Alexander Universität
Erlangen-Nürnberg), Tim Lohse (Hochschule für Wirtschaft und Recht Berlin
and MPI for Tax Law and Public Finance),
James Alm (Tulane University, USA), Paul
E. Carrillo (George Washington University, USA), Tuomas Kosonen (VATT Institute
for Economic Research, Finland), Carlos
Scartascini (Inter-American Development Bank, Argentina), Monica Singhal
(Harvard Kennedy School, USA), Erik O.
Sørensen (NHH Norwegian School of
Economics and Business Administration, Norway) and Adnan Khan (London
School of Economics, UK).
Understanding Tax Havens
Organisers: Kai A. Konrad, Guttorm
Schjelderup (NHH Norwegian School of
Economics and Business Administration,
Norway)
Date: 22–23 January 2014
Tax havens and the logic of their interactions with individual or corporate taxpayers, with accounting firms and nonhaven countries are not easy to understand. This interdisciplinary workshop
brought economists, accountants and
legal scholars together to make further
steps in this direction. Among the presenters were Petro Lisowsky (University
of Illinois at Urbana-Champaign, USA),
Niels Johannesen (University of Copenhagen, Denmark), Tim Stolper, Prem
Sikka (University of Essex, UK), Thomas
Gresik (University of Notre Dame, USA),
Tina Søreide (University of Bergen, Norway), Dirk Schindler (NHH Norwegian
School of Economics and Business Administration, Norway) and May Elsayyad
(Allianz SE and MPI for Tax Law and Public Finance).
Contest Theory and Political
Competition
Organisers: Kai A. Konrad, Dan Kovenock (Chapman University, USA)
Date: 4–5 September 2014
The theory of contests has made major
progress in the last 20 years. Independently and in parallel, the study of political competition is an important research
area in political science. These two lines
of research more recently crossed and
joined. This workshop aimed at a union
of key figures from both lines of research,
and of persons working at the crossing.
Presenters at this event were Pierre C.
Boyer (University of Mannheim), Brian
Roberson (Purdue University, USA), Alexander Hirsch (California Institute of Technology, USA), Tilman Klumpp (University
of Alberta, USA), Andrea Mattozzi (European University Institute, Italy), James
Snyder Jr. (Harvard University, USA),
Ronny Razin (London School of Economics, UK), Ivan Pastine (University College
Dublin, Ireland), Kenneth Shotts (Stanford
University, USA), Stergios Skaperdas (University of California, Irvine, USA), Daniel
Diermeier (University of Chicago, USA),
Christopher Li (Northwestern University,
USA), Karl Ove Moene (University of Oslo,
Norway) and Mattias Polborn (University
of Illinois, USA).
145
Joint seminar with the group of Bruno
Frey, Schliersee, 12–14 May 2013.
The interdepartmental lecture series features about 6–10 international researchers of outstanding scholarship from tax
law and from public economics per year.
The series is a joint initiative of both Departments of the Institute.
As a further format for mutual intellectual exchange the Institute organises or
co-organises annual workshops in which
the Department meets with other, similar groups. Within the reporting period,
such meetings took place on a yearly basis with the research group of Matthias
Sutter (University of Innsbruck, Austria),
the research group of Werner Güth (Max
Planck Institute for Economics, Jena) and
the research group of Bruno Frey (CREMA, Zurich, Switzerland).
The Department is also a member of
a collaborative project on “Governance and the Efficiency of Economic
Systems”. The part of this project
which is pursued at the MPI is entitled
“Konflikte in Organisations- und Steuerungsproblemen” (conflict in governance problems). This project is funded as
a Sonderforschungsbereich-Transregio
by the German Research Foundation
(DFG). Part of the interaction is a series
of regular meetings, a common internet
platform, a common monthly newsletter and an exchange of researchers on
an individual basis. The project is in its
third (and last) funding period that lasts
until December 2015. Partner institutions of this project are the University of
Mannheim, the University of Bonn, the
Freie Universität Berlin, the HumboldtUniversität zu Berlin and the LudwigMaximilians-Universität in Munich.
The Department collaborates (jointly
with the Department of Tax Law) in a
project entitled “Steuerpolitik in der
EU im Umfeld neuer Fiskalinstitutionen
und Abstimmungsverfahren” (Tax Policy
in the EU in an Environment with New
Fiscal Institutions and Coordination Processes). Other partners in this project
are at the Verwaltungshochschule at
Speyer and at the University of Oxford.
This project has led to a number of joint
conference meetings in Mannheim and
a stimulating exchange on research results. The project ends in 2015.
The Department collaborated with researchers at the WZB Berlin Social Science Center, the ifo-Institute Dresden
(Marcel Thum) and the ZEW (Lars Feld,
Friedrich Heinemann), the Free University of Brussels (Benny Geys), and the
Freie Universität Berlin (Ronnie Schöb)
on a research project entitled “The Future of Fiscal Federalism”. The project
ended in 2012. A group of six Ph.D.
students was jointly supervised by this
group of researchers who study ques-
tions of fiscal competition and on federal
governmental structures, either inside a
country or as federations of countries.
The programme started in 2009 and
ended in December 2012.
The Department took part in a research
collaboration with the Deutsche Akademie der Technikwissenschaften (acatech)
in a project entitled “Adaptation Strategies in Climate Policy”. In this project,
acatech brought together a highly interdisciplinary group of experts from other
research institutes from a large number
of disciplines and of representatives of
stakeholders from interest groups and
major companies to conduct a high level
report on “Anpassungsstra-tegien in der
Klimapolitik” (adaptation strategies in climate policy). This report was published
as an acatech Position report in September 2012. The project was steered
by a committee consisting of Ulrich von
Deessen, BASF SE, Rolf Emmermann,
Deutsches
GeoForschungsZentrum
Potsdam, Reinhard Hüttl, Deutsches
GeoForschungs-Zentrum,
Potsdam,
acatech Präsident, Kai A. Konrad, Volker
Mosbrugger,
Senckenberg
Gesellschaft für Naturforschung und Universität Frankfurt, Ekkehard D. Schulz, former ThyssenKrupp AG and Fritz Vahrenholt, RWE Innogy GmbH.
Through personal links the Department
is involved in policy-oriented research
by the Council of Scientific Advisors to
the Federal Ministry of Finance. Kai A.
Konrad was Chair of this council for two
office periods from 2011 to the end of
2014. In this time period the Council
advised the Federal Ministry of Finance
on a number of topics. The reports or
publications that emerged from the time
period 2012–2014 are listed in section
B, from pages 192. A second link with
the Ministry of Finance is through Nadja
Dwenger who is a member of the young
experts group which meets regularly
with members of the Ministry.
The researchers of the Department were
granted several awards, prizes, and memberships during the reporting period. An
overview of all accolades can be found
on page 218.
Nadja Dwenger (middle) with Ronnie
Schöb (left) and Stefan Traub (right)
from the Verein für Socialpolitik.
Nadja Dwenger, senior research fellow at the MPI for Tax Law and Public
Finance, was granted several awards
in the reporting period. Honoured as
a Schöller Fellow 2013, she received
funding totalling 20,000 € to carry out
research on tax compliance. One year
later, Nadja Dwenger was honoured
with the Schmölders Prize from the Verein für Socialpolitik (VfS). The prize was
147
On 27 November 2014, the new members of the humanities and social and
behavioural sciences section of Leopoldina were officially welcomed and given
their membership certificates. Kai A.
Konrad (left) is pictured above with Leopoldina President Jörg Hacker (right).
awarded for the paper “Extrinsic and
intrinsic motivations for tax compliance:
Evidence from a field experiment in Germany”, which she wrote together with
her co-authors Henrik Jacobsen Kleven
from the London School of Economics,
Imran Rasul from the University College
London and Johannes Rincke from the
Friedrich-Alexander-University ErlangenNürnberg.
Kai A. Konrad was elected membership
to various academies in the reported period: In 2012 he was elected as a Member of the National Academy of Science
and Engineering (acatech), in 2013 he
became a Member of the Academia Europaea and the German National Academy of Sciences, Leopoldina. In 2014
Kai A. Konrad became a Member of the
Berlin-Brandenburgische Akademie der
Wissenschaften.
We turn next to a survey on basic research. The researchers in the Department addressed questions in the area
of public finance. Much of the work
focussed more narrowly on taxation issues. Similar to previous activity reports,
we do not survey all the results here; the
complete list of publications and working
papers can be found further below. Instead, we report the results of three major research areas. These can be broadly
grouped into “Understanding Taxation
and Tax Compliance”, “International Public Finance” and “The Political Economy
of Distribution and Conflict”.
III Understanding Taxation and
Tax Compliance
Salmai Qari accepted a professorship
in econometrics at the Berlin School of
Economics and Law.
The aim of our work in this area is to
reach a better understanding of how taxation affects human behaviour both as
private individuals and as decision makers in firms, and a better understanding
of what drives tax compliance decisions.
Analytical and game theory tools, econometric approaches, laboratory and field
experiments are applied in the Depart-
ment to research questions within this
area.
1. Tax Compliance
As emphasised by Andreoni et al. p.
821 (Andreoni, James, Brian Erard, and
Jonathan Feinstein. “Tax compliance”.
Journal of Economic Literature 1998,
36(2), 818-860) in their survey, tax compliance behaviour is not well-described
as a risk-taking activity only. Behaviour
differs from what individuals would
do in a pure money gamble and what
would be predicted by a narrow theory
of crime and punishment in the line of
reasoning of Gary Becker. Understanding tax compliance is more difficult and
requires a broader research approach.
A great deal of work has been devoted
to assess a large number of factors that
are important for taxed subjects in their
decision as to whether or not to report
truthfully and comply with their legal tax
obligations. Intrinsic motivations such as
moral attitudes, norms, religiosity, family status, profession, and other factors
may play a significant role. Research in
the Department in the reporting period
contributed further to this research approach.
Nadja Dwenger, Henrik Kleven, Imran
Rasul, and Johannes Rincke exploit a
unique setting for making progress on
understanding tax compliance: the local church tax in Germany. As they show
in their paper entitled “Extrinsic and
intrinsic motivations for tax compliance: Evidence from a field experiment
in Germany” (under review), tax evad-
ers, compliers and donors can coexist in
the local church tax system and can be
distinguished from each other. The local
church tax is a specific tax that is not actually enforced by the authorities. Compliance in the absence of more specific
treatments provides data on compliance
behaviour and the actual tax payment
in the absence of enforcement can be
seen as a direct measure of intrinsically motivated tax compliance. Starting
from this zero enforcement baseline, a
randomised field experiment is used to
add deterrence or recognition into the
system. This allows Nadja Dwenger and
Nadja Dwenger
her co-authors to study whether policies aimed at either extrinsic motivation
(deterrence) or intrinsic motivation (recognition) have qualitatively different effects on agents who have revealed each
of those motivations in the baseline
treatment.
The main empirical findings of this work
are the following. First, a significant
fraction of individuals comply in the
absence of deterrence/enforcement,
where compliance should be expected
to be zero absent intrinsic motivations.
Around 20 per cent of individuals pay at
least the true taxes owed. This suggests
149
that intrinsic motivation is important.
The remaining 80 per cent of individuals evade taxes and most of them fully
evade, and so the vast majority behave
as extrinsically motivated taxpayers
consistent with the Becker-AllinghamSandmo framework of crime and punishment. Second, there is sharp bunching at
exact compliance in the zero deterrence
baseline. Further analyses suggest that
bunching at exact compliance is driven
by duty-to-comply preferences. Third,
announcing a zero audit probability (the
Figure taken from Nadja Dwenger, Henrik Kleven, Imran Rasul, and Johannes
Rincke, “Extrinsic and intrinsic motivations for tax compliance”: Distribution of
tax liabilities and tax payments.
status quo) has only a small impact on
compliance, implying that there is very
little misperception on average. In fact,
less than 5 per cent of baseline compliance can be attributed to a misperception of the audit probability, and hence
this is not an important confounder in
the measurement of baseline intrinsic
motivation. Fourth, tax simplification
and deterrence have strong effects on
compliance for baseline evaders, but
small and mostly insignificant effects
for baseline donors. Finally, the provision of compliance rewards has fundamentally different impacts on baseline
donors (who increase their donations)
and baseline evaders (who increase
their evasion). That is, whether recognition for compliance raises or reduces
tax payments hinges on what motivates
taxpayers in the first place, with positive
effects on the intrinsically motivated and
negative effects on the extrinsically motivated taxpayers. These qualitative patterns arise irrespective of the exact form
of the compliance reward offered in the
different treatments, be it in terms of
social recognition, entry into monetary
prize draws, or their combination. This
suggests that the behavioural effects are
driven by what such compliance rewards
signal about the tax institution rather
than by the social/private nature of the
reward. A natural interpretation is that
rewarding taxpayers for contributing
to the public good (rather than punishing them for not paying their taxes)
signals the voluntary aspect of a poorly
enforced tax system (and so positively
affects the warm glow of donor types)
and at the same time downplays the
mandatory aspect of a legally binding tax
system (and so may affect evader types
negatively). All of these findings can be
explained by a model of tax compliance
provided in the paper that unifies the
standard Becker-Allingham-Sandmo approach (strengthening extrinsic motives
for tax compliance) and the Andreoni
warm-glow model of pro-social behaviour (capturing intrinsic motivation).
viduals’ intrinsic motivation to contribute to the public good.
The study on extrinsic and intrinsic motivations for tax compliance raises the
question on the optimal financing mode
of public goods. In another randomised
field experiment in the paper “Do taxes
crowd out intrinsic motivation? Fieldexperimental evidence from Germany”
Pierre Boyer, Nadja Dwenger, and Johannes Rincke focus on the trade-off
between a tax-based and a voluntary
contribution-based financing of public
goods and investigate how an individual’s motivation is affected if a voluntary
contribution becomes compulsory. To
this end, they consider the church levy,
which is a fee collected by the Catholic
Church in Germany as a charitable donation on a purely voluntary basis—despite
the fact that it is legally a tax. Starting
from a baseline where the church levy
is collected as a pure charitable donation, individuals are informed that the
church levy is in fact a tax. A theoretical
model developed in the paper highlights
that such a tax framing creates a discontinuity in individuals’ motivation and
will heterogeneously affect individuals,
depending on their initial motivation to
contribute. This is also found empirically:
While those who regularly contributed
before do not respond to the imposition
of the legal norm, weakly intrinsically
individuals, who contributed only from
time to time, significantly reduce their
payments. The paper provides among
the first evidence from the field showing
that external incentives (partly) crowd
out intrinsic motivation. Financing public
goods by taxes can thus impair the indi-
A second set of work on tax compliance in the reporting period explores
controlled laboratory experiments.
Fangfang Tan together with Andrew Yim
studied how to conduct tax audits more
efficiently in light of the huge resources
devoted to reduce the tax gap. The project started and was described in more
detail in the report for the previous audit
period. The results are published now
as Fangfang Tan and Andrew Yim, “Can
strategic uncertainty help deter tax evasion? An experiment on auditing rules”
(Journal of Economic Psychology 2014,
40, 161-174). They compare two audit
rules. One is the standard audit rule
that suggests a given probability for an
audit. A novel feature of their alternative rule is that since the tax authority
only conducts a fixed number of audits,
the actual audit probability faced by a
taxpayer is endogenously determined
by the evasion decisions of all other
taxpayers. Consequently, a taxpayer has
to infer the audit probability by forming
expectations on others’ decisions. This
causes strategic uncertainty. They find
that the deterrence effect of this modified audit rule is as strong as that of a
traditional rule. However, their rule is
more cost-effective, for two reasons.
First, it conducts fewer audits to attain
the same level of deterrence. Second, it
uses the public budget more efficiently.
The budget-usage ratio, which is defined
as the percentage of resources actually
used in auditing for a given budget, is
higher for their rule. They also explore
the effect of strategic uncertainty on
151
taxpayers’ decisions. They find that if the
taxpayers are highly uncertain of others’
evasion decisions, they are more likely to
choose to honestly report their income
instead of cheating on taxes. This result
is consistent with previous experimental
results on coordination problems.
Fangfang Tan
Punishment threats, such as fines, play a
major role in the early theory of tax compliance, such as in the Allingham-Sandmo
framework. Fangfang Tan and Erte Xiao
(2014) conduct experiments to better
understand compliance. They focus on
a problem of voluntary cooperation (e.g.
such as the provision of public goods). It
is known in this context that compliance
relies not only on second-party punishment in which only an implicated party
can punish a wrongdoer, but perhaps
more importantly on third-party punishment, in which those who sanction norm
violators do not directly benefit from
their decisions. Erte Xiao and Fangfang
Tan (2014) address the following two
questions: (1) To what extent do third
parties use punishment as retribution or
to deter defectors? (2) How does the answer to the first question differ according
to whether the third party is a group or
an individual?
The main finding is that groups are more
likely to punish instrumentally than
individuals: Groups are more likely to
approve punishment towards defectors
when the punishment has a deterrence
effect than when the punishment can
only be retributive. In contrast, individual third parties punish similarly for both
purposes. Furthermore, a significant
amount of proposed punishment is negated by the third party. However, a new
result of this study is that when the third
party is a group, the punishment disapproval rate is even higher, even though it
is a costless decision to punish.
Whether punishment is perceived to be
legitimate determines how effectively
it can signal social norms and promote
conformity. Erte Xiao and Fangfang Tan
(2014) also present novel experimental
evidence that requiring justification
could promote the legitimacy of thirdparty punishment and curb corrupt punishment behaviour. In the baseline nonprofitable punishment treatment (NPP),
the punishment decision of the third
party is independent of the decision itself – the party only receives a fixed payment for the task. In the profitable punishment treatment (PP), the third party
earns extra money if the party punishes
the sender, regardless of whether the
sender has sent a false message to the
receiver. Previous literature reports that
people are less likely to view punishment
as signalling a norm violation in PP than
NPP treatment. This paper introduces a
justification treatment. Compared to PP,
the only difference in the justification
treatment is that the third party must
explain its decision (whether to punish
or not punish the sender). Legitimate
punishment counts if and only if a sender
violates a truth-telling norm.
Erte Xiao and Fangfang Tan find that
justification increases legitimate punishment to a level similar to the NPP treatment. Moreover, compared with the PP
treatment, the senders are significantly
more likely to tell the truth in the justification treatment, and the receivers are
more likely to perceive punishment as
signalling a norm violation. These findings shed light on the underlying mechanisms of the role of justification on legal
enforcement and policy making.
A further line of research on tax compliance was directed towards an assessment of a different non-monetary incentive of taxpayer subjects. Much of this
line of research was conducted and reported in the previous reporting period.
Using several waves of the International
Social Survey Programme (ISSP) dataset
the studies identified patriotism as an
important determinant for taxpayers’
behaviour and the transmission mechanisms by which these determinants affect
the fiscal capacity of states. The results
of this research were published in this
reporting period. One of the studies concentrates on international aspects and
cross-border mobility, the other study
concentrates on individuals’ perceptions
about the legitimacy of tax avoidance.
In the article “Patriotism, taxation and
international mobility” by Salmai Qari,
Kai A. Konrad, and Benny Geys (Public
Homepage of the International Social Survey Programme (ISSP) (http://www.issp.
org).
Choice 2012, 151(3-4), 695-717) the
authors establish a strong relationship
between national identity (self-assessed
patriotism) and individuals’ tax burden.
While this study does not identify the
channels by which governments may
pursue this actively or unconsciously, the
data analysis reveals a positive relationship between the patriotism of persons
and the tax burden they bear, in line with
the idea that a less mobile tax base can
be taxed more heavily.
Related to this result, research by Kai A.
Konrad and Salmai Qari, entitled “The
last refuge of a scoundrel? Patriotism
and tax compliance” (Economica 2012,
79(315), 516-533) shows that more
strongly patriotic subjects are indeed also
more tax compliant. As the strong correlation between the attitude towards tax
compliance and patriotism could be the
result of different directions of causality,
the analysis also uses an instrumental
variables approach. It shows that there is
good reason to believe that the relationship is partially causal, with patriotism
inducing higher compliance.
research in Public Economics
153
Tax compliance is a complex matter with
difficult lines to draw between avoidance on the one side, and evasion and
tax fraud on the other, and with many
further dimensions. To study the behavioural aspects of the compliance
decision, Kai A. Konrad, Tim Lohse, and
Salmai Qari chose to approach a more
straightforward problem in the laboratory. In experiments they studied a
problem in which subjects have to make
a simple decision between two alternatives: whether to declare honestly or
not. This situation is, for instance, very
close to the decision which travellers
face in the context of customs compliance. The start of this work was actually reported in the previous reporting
period, in which several tax/customs
compliance experiments focussing on
the importance of face-to-face encounters between the taxable subjects were
executed in the laboratory with student
research assistants taking the role of tax
inspectors. We provide insights into the
role of the self-perception of taxed subjects about how their observed appearance affected tax inspectors’ decisions
regarding a possible audit. We also videotaped the interviews conducted on this
question. These videotapes were the basis of two further experiments that were
conducted in the reporting period. One
experiment showed individuals when
they made their tax reports to tax inspectors. It showed individuals who reported
having a low income. Some of these individuals truthfully declared that they had
a low income (resulting in zero taxation).
Other individuals declared having a low
income, whereas their true income was
high and, if honestly declared, caused
tax liabilities. Sets of 40 video clips were
shown to 231 other laboratory subjects
who had to assess whether a given clip
showed a truthful or an untruthful report.
The major findings were published as
“Deception detection and the role of selfselection” (Journal of Economic Behavior
& Organization 2014, 107, 25-39). First,
there is much heterogeneity among the
taxpayer subjects as regards whether
they are assessed as truthful or untruthful in their reports. Some taxpayer subjects are systematically assessed as truthful, other taxpayers as untruthful. These
assessments are mostly independent of
whether taxpayers were actually truthful
in their reports or untruthful. Assessment
biases are hence caused by characteristics that are tied to the taxed subjects,
rather than to whether they declare
truthfully or untruthfully. Second, there
is mild evidence showing that taxpayer
subjects are aware of their appearance
as truthful or untruthful. Third, there is
evidence of self-selection of taxpayers
with high income when they make their
declaration decision. It is the taxpayer
subjects who appear truthful who selfselect and choose to underreport their
true income.
A follow-up study by Nadja Dwenger,
Kai A. Konrad, and Tim Lohse is currently
under way that uses a within-subjects
design. It allows for the study of truthfulness assessments by student subjects
who watch a set of video clips for a set of
taxpayer subjects for which two declaration decisions are on tape: one in which
the subject truthfully reports low income,
and one in which the same subject has
high income and decides to untruthfully
report low income. Evidence from these
studies suggests that the taxpayer subjects do not appear to be more truthful
when they truthfully report low income,
compared to when their true income is
high and they falsely report low income.
While experimental and empirical results
on compliance decisions and the possible non-material incentives which drive
them were an important part of the research in the Department, much work
was devoted to the theory that studies
tax evasion and tax auditing as incentive problems from a contract theory
perspective. Important contributions to
these questions included the Ph.D. thesis
by Philipp Meyer-Brauns.
In his paper “Multitasking in corporate
tax evasion” he studies corporate tax evasion. Using a principal-agent model with
multitasking, the paper considers how
contracting between a non-specialist
firm-owner and a specialist tax manager
influences the tax evasion game when
the manager decides on both the quantity and quality of tax evasion. Quantity is
defined here as the extent or the amount
of underreporting. Quality is defined as
a form of self-insurance activity that reduces the expected fine for evasion in
case of an audit. Higher quality may be
interpreted as resorting to more sophisticated or complex ways of evasion, for example. The paper first characterises the
optimal remuneration contract between
a tax manager and firm-owner in such a
setting. It finds that asymmetric information between the two contracting parties
reduces both the optimally chosen quan-
tity and quality of tax evasion in equilibrium. The work then determines the
government’s optimal tax enforcement
policy and examines how this policy
changes with the extent of asymmetric
information between the principal and
agent. Its main finding is that due to the
reduction of evasion quality, tax enforcement may become more effective as a
result of asymmetric information inside
the firm. Consequently, tax enforcement
may be stricter where firms enter principal-agent relationships to evade taxes,
rather than more lenient as suggested by
earlier studies.
In his work entitled “Financial contracting
with tax evaders” Philipp Meyer-Brauns
studies how financial contracting and
tax evasion interact. This paper extends
the classic Townsend-Gale-Hellwig costly
state verification model of financial contracting to allow for tax evasion by the
borrowing entrepreneur. Because tax
evasion is illegal, the potential proceeds
from it are not contractible. The downside in case of detection, however, is
potentially harmful to the investor. That
155
is because fines for evasion may exhaust
the entrepreneur’s funds and thus constrain her ability to repay the investor. In
this context, the paper finds that standard debt contracts are no longer optimal.
Instead, the optimal contract derived in
this work combines elements of debt
and equity and is less efficient than a
standard debt contract.
In a third project entitled “Optimal auditing with heterogeneous audit perceptions” Philipp Meyer-Brauns studies how
heterogeneous perceptions of audit risk
by taxpayers influence the government’s
optimal tax audit policy. The paper finds
that a taxpayer population exhibiting
such heterogeneity requires a substantially different optimal audit strategy. In
particular, the equilibrium audit intensity may increase or decrease as a result
of heterogeneity in audit perceptions,
depending on how costly audits are for
the government. For instance, high audit
costs imply that the government’s main
trade-off in choosing its audit policy is
Conference on Tax Compliance in
Field and Laboratory Experiments,
4–5 November 2013.
between economising on audit costs and
inducing honesty. More dispersed perceptions of the true audit probability are
found to weaken the honesty-inducing
effect of a marginal increase in tax audit
probability, but leaves the additional
audit costs unchanged. This tilts the government’s trade-off towards economising on audit costs, which in turn leads to
less intense audits as a result of higher
heterogeneity in perceived audit risk.
2. Tax Incidence
Questions of tax incidence and the distribution of the burden of taxation belong
to the classic topics in the analysis of taxation. It is one of the important results
within public finance that statutory incidence (the description about who physically has to pay a tax) and economic incidence (the description about who bears
the economic burden of a tax) can be,
and often are, two very different things.
To study economic incidence and how it
differs from statutory incidence, the tools
of modern industrial organisation and an
understanding of the functioning of markets are indispensable. Market structure
is decisive for economic incidence, and
results on economic incidence are often
counterintuitive or at least contradict the
layman’s perceptions. Theory, but also
laboratory experiments can contribute
to clarifying the effects. The experiments
on “Taxation and market power” by Kai
A. Konrad, Florian Morath, and Wieland
Müller (Canadian Journal of Economics
2014, 47(1), 173-202) was described in
the previous activity report. It addresses
an aspect which is often misperceived
in the public debate and in the financial
press: the relation between the market
power of firms and their ability to shift
tax increases onto consumers.
In the working paper entitled “The taxation of bilateral trade with endogenous
information”, Tri Vi Dang and Florian
Morath (2013) study questions of tax incidence and the efficiency effects of taxation in decentralised markets in which
agents may acquire information before
they decide whether to trade. Investments in information acquisition play, for
instance, a crucial role in financial markets. Their work shows that the policy
conclusions on the efficiency effects of a
financial transaction tax and of a capital
gains tax may change when accounting
for the implications of taxation for information acquisition. They consider a
model of decentralised bargaining and
trade such as trade in over-the-counter
markets and show that taxation has two
effects: a direct effect on the equilibrium trading price; and an indirect effect
which works through the trading parties’
equilibrium choices of whether to invest
in information acquisition. As a result, a
transaction tax leads to more information acquisition and to less trade in equilibrium, while a capital gains tax leads to
less information acquisition and to more
trade in equilibrium. In contrast, a capital gains tax has no effect on equilibrium
trade if private information is exogenous.
The overall welfare effects depend on
whether bilaterally beneficial trade is
socially optimal and the policy implications differ diametrically for the two tax
instruments considered. By preventing
information acquisition and hence prob-
lems of asymmetric information, a capital gains tax can be efficiency-enhancing.
On a closely related topic, Michael
Hilmer analyses and compares different fiscal instruments that can affect
managerial compensation and that were
discussed in many countries and implemented by some governments: (i) taxes
which managers (agents) need to pay on
the bonuses received, (ii) limited deductibility of bonuses from company profits
and (iii) a corporate income tax (CIT).
Based on a principal-agent framework in
which the agent’s limited resources generate the second-best problem, he explores how the three tax instruments affect managerial incentives and how they
change the design of incentive contracts
used in equilibrium. For a given compensation structure, he finds that a bonus tax affects the equilibrium bonuses
paid by firms. It decreases net bonuses
that are chosen in the equilibrium and
reduces managerial effort. However, allowing for an endogenous adjustment as
it occurs if the principal-agent contract is
chosen optimally, for incentive contracts
used in equilibrium, both a bonus tax
and the limited deductibility of bonus
payments from company profits reduce
(and distort) the manager’s effort and
net bonus. Gross bonus payments may
increase when a bonus tax is introduced.
Nevertheless, limited deductibility and
bonus taxes are close substitutes in
terms of welfare. Both lead to a welfare
loss compared to a CIT raising the same
tax revenue.
This research project has a starting
point that is a contract equilibrium that
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Michael Hilmer
is second-best from the perspective
of the private sector in the absence of
taxes. In this framework the CIT is a pure
profit tax and does not distort the firm
owners’ decisions, and bonus taxes and
limited tax deductibility of managerial
compensation cannot improve upon a
CIT. This starting point can be seen as
an important benchmark. It may be important, however, to study bonus taxes
and constraints on tax deductibility in
set-ups in which a market failure prevails
in the laissez-faire situation. Michael
Hilmer analyses these in the presence of
a systemic risk externality. He considers
a financial market with highly interconnected financial institutions. In a simple
symmetric principal-agent model with
two banks, owned by different groups
of shareholders, he assumes these bank
insolvencies are systemic only if several
banks simultaneously run into trouble,
causing a too-many-to-fail externality:
the banks receive a bailout only if several banks fail jointly. Thereby, the model
generates incentives for herding and collective moral hazard. These may prevail
even if each single bank is small.
In his model framework a wealth-constrained manager is the only decision maker who knows about the distribution of returns of a feasible project. The bank’s owners have to use incentive payments such
as a bonus in order to align managers’
interests with stockholders’ interests. In
combination with the bailout externality,
this leads to a number of results. If banks
can anticipate bailouts, they can coordinate on an equilibrium in which they collectively incentivise the managers to take
excessive risks. A bonus tax can prevent
this excessive risk-taking. It reduces the
risk-taking of the taxed bank and, consequently, rules out the equilibrium with
excessive risk-taking by both banks and
reestablishes market discipline. This is
also true if the bonus tax is implemented
unilaterally for one bank only.
Michael Hilmer also studies the role of
these taxes in a dynamic framework
in which the point of departure of his
analysis is characterised by what is often
referred to as “short-termism”. He examines in which respect (i) the externality
of a bailout and (ii) the introduction of
a bonus tax on short-term bonus payments influence the managerial timing
of investment strategies and the relationship between long-term and shortterm compensation. He uses a model
that is an adapted version of a model on
short-termism in the literature. In this
framework, investment opportunities
last for two periods and the manager can
choose the degree of short-termism. To
shift profits from future to more immediate periods is costly for the manager, and
such increases in expected short-term
profits also come at the expense of ex-
pected long-term profits. As this shorttermism is harmful for the bank, it should
be in the bank’s best interest to prevent
any short-termism chosen by the manager.
However, an anticipated bailout can make
the bank willing to tolerate short-termism
more often and to a higher degree. While
it is indeed in the bank’s interest to prevent
short-termism by using an appropriate
compensation structure in the absence of
a bailout, in the presence of a bailout it is
more profitable for the bank to pay higher
short-term payments and to tolerate the
negative consequence of increased shorttermism. Nevertheless, an appropriate tax
on short-term bonuses is found to change
the determinants of incentive provision
towards long-term bonuses and, thus, can
induce the bank to internalise the costs of
a bailout. Finally, inefficient short-termism
can be reduced.
Overall, these findings by Philipp MeyerBrauns and by Michael Hilmer shed
new light on questions on which many
premature common sense conclusions
are prevalent in the public debate. The
findings are of high policy relevance and
contribute to a debate on the benefits of
certain tax policies that emerged in the
context of the recent financial crisis.
3. Optimal Taxation
Economic incidence analysis predominantly takes a positive point of view. It
describes who bears the economic consequences of a given tax. This perspective offers insights into the mechanisms
by which taxes affect decision makers
as a function of the market framework,
informational constraints and the set of
feasible contractual arrangements. Optimal taxation, in contrast, typically starts
with a normative objective which, in
typical cases, is a society’s welfare function. The research on optimal taxation
can then be seen as solving “engineering
tasks”, where the economist is the engineer for a welfare-maximising government or a welfare-maximising politician
who seeks to implement a tax policy that
maximises this societal welfare function.
This classical area of public finance dates
back more than 100 years. The field is
associated with work by Nobel prize
winners such as James Mirrlees, Finn E.
Kydland, and Edward C. Prescott. The
early work by Mirrlees “An exploration in
the theory of optimum income taxation”
(The Review of Economic Studies 1971,
38(2), 175-208) addressed the question
of how to design a redistributive tax on
personal income if individuals’ true earnings ability is their private information,
and if the individuals can react to a tax by
changing their work effort. Economists
have continued to study variants of this
key question for decades, but the work
had a major revival in the last 15 years
with economists including Robin Boadway, Raj Chetty, Peter Diamond, and Emmanuel Saez.
Within the Department, Aart Gerritsen,
together with Bas Jacobs (Erasmus University Rotterdam), completed further
research on this question. More specifically, they ask whether a binding minimum wage is an appropriate instrument
for redistribution in this context: should
a government implement a binding mini-
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Aart Gerritsen
mum wage if it also has access to progressive taxation to redistribute income?
They theoretically show that a minimum
wage does redistribute from skilled workers to unskilled workers by flattening the
wage distribution. But such redistribution could also be replicated by an adjustment of the progressive tax system. A
minimum wage distinguishes itself from
progressive taxation by raising the costs
of hiring unskilled workers, which yields
two separate effects on social welfare.
On the one hand, as firms will be less
willing to hire unskilled workers, a minimum wage leads to higher involuntary
unemployment – a welfare loss. On the
other hand, as unskilled workers want to
avoid involuntary unemployment, they
will invest more in skills. As higher skilled
workers tend to pay more taxes, this increase in education constitutes a welfare
gain. A minimum wage is desirable if the
social welfare gains from more education
outweigh the social welfare losses from
higher unemployment.
Aart Gerritsen and Bas Jacobs also develop an empirically measurable condition
under which a minimum-wage increase
is desirable. Three measures turn out to
be crucial: the tax-revenue gains associated with an additional skilled worker,
the tax-revenue losses associated with
an additional unemployment person,
and an elasticity which indicates how
the number of skilled workers responds
to an increase in unemployment. Using
OECD data for tax-revenue gains and
losses, they conclude that for almost all
OECD countries under consideration, a
minimum wage increase would be desirable only if a percentage point increase
in the unemployment rate leads to higher educational enrollment of at least 0.6
percentage points. Only for the United
States, enrollment rates should increase
by 0.4 percentage points. Within the
empirical literature, the best estimates
of the unemployment-enrollment effect
tend to lie between 0.1 and 0.6. This
suggests that a minimum wage decrease
is desirable for all countries under consideration – except possibly the United
States. If such a reform is accommodated
by compensating tax adjustments, it can
lead to both more tax revenue, as well
as utility gains for individuals who manage to obtain a job due to lower wage
costs. A reduction of the minimum wage
could thus be part of a Pareto-improving
policy reform, leading some groups
of individuals to be better off and no
other group to be worse off. Within their
model context they also conclude that,
for countries without legally binding
minimum wage – such as Germany at
the time of the research, Austria, Italy,
or the Nordic countries – implementing
one is not desirable.
Next to minimum wages, another tool
that may be relevant in the context of
optimal taxation is rationing. Rationing
may, however, also come into the picture
as a constraint rather than as an instrument. An important example of rationing is involuntary unemployment and is
studied by Aart Gerritsen in the context
of optimal taxation. Involuntary unemployment is characterised by the supply of labour to exceed the demand for
labour, without market forces adjusting
towards a market clearing equilibrium.
A typical feature of the rationing scheme
that applies in the state of involuntary
unemployment is that some of the unemployed would derive more satisfaction
from a job than some of the workers who
do manage to obtain a job. Now consider
taxes. Higher tax rates lead to reduced
incentives to supply work. Starting from
a given equilibrium rationing state, this
causes a selective exit: some workers
change to work less or not at all. At the
margin, the increase in income taxes
causes an interesting selection effect. It
is the persons who derive relatively little
utility from being employed who decide
to work less or quit. They create employment for some of the unemployed, and
the newly hired persons may not be persons close to indifference, but individuals
who derive a non-zero rent from becoming employed. Similar results apply to
unemployment benefits. In the absence
of involuntary unemployment, higher
benefits lead to less labour supply and
thereby to an efficiency loss. However,
in the presence of involuntary unemployment, higher benefits lead workers
to create jobs for the unemployed who,
on average, derive more well-being from
it. In other words, by raising taxes and
benefits the government may substitute
voluntary unemployment for involuntary
unemployment, thereby generating an
efficiency gain.
Unlike in the conventional equityefficiency trade-off, taxes and benefits
may lead to both improved equity and
improved efficiency here. Within this
analytic framework, the policy recommendations from these considerations
would be to raise income taxes for
labour-market segments that are characterised by high involuntary unemployment, and use the additional revenue to
increase unemployment benefits.
Applied to a more dynamic perspective that takes into account the ups and
downs of economic activity, the results
suggest that government should raise income taxes and unemployment benefits
in times of high-unemployment recessions, and lower them in more prosperous economic times. These conclusions
also bear implications for government
policy that is aimed at increasing labourmarket participation. If the labor market
is characterised by involuntary unemployment, it need not be desirable to
activate the unemployed. This is the case
if such a policy would only replace people who have a net surplus from working, compared to being on welfare by
persons who are just indifferent about
whether to be on welfare or to enter the
labour market.
Another finding is that a standard result
on the economic incidence of labour
income taxes need not hold: the irrel-
161
Workshop on Taxation and Redistribution, 6 June 2012.
evance of whether these taxes are collected from employees or employers.
In both cases the tax would lead to the
same decrease in workers’ net wages
and increase in firms’ labour costs. The
conventional wisdom is based on the assumption of flexible wages, an assumption that does not square well with many
types of involuntary unemployment. In
the presence of involuntary unemployment, higher employee taxes may lead
to both equity and efficiency gains (as
described above), but higher employer
taxes may lead to even less labour demand and higher unemployment in this
framework, and therefore to an efficiency loss.
Standard rational choice theory assumes
that people make decisions in line with
their preferences. This assumption has
often been subject to criticism from
psychologists and, more recently, also
by economists. This makes it worthwhile
to study the welfare effects of taxation if
the fundamental rational choice assumption is relaxed. Pursuing this objective as
an exercise in behavioural economics,
Aart Gerritsen finds that on top of the
standard equity and efficiency effects,
taxes might serve to ‘correct’ people’s
‘mistaken’ behaviour. For example, when
it comes to labour income taxes, higher
marginal tax rates cause workers to work
less. Apart from the standard efficiency
effects, such a reduction of labour supply may be to the benefit of workers if
workers tend to work harder than ‘what
is good for them’ and is less beneficial if
workers tend to work less than ‘what is
good for them.’
Whether people indeed work ‘too much’
or ‘too little’ is a difficult question.
Aart Gerritsen attempts to address this
question by using British panel data on
people’s subjective life satisfaction as
a measure of well-being. On the basis
of these and other data, he determines
how this measure of well-being depends
on both net income and working hours.
This allows him to calculate the ‘wellbeing optimal number of working hours’
for every individual. Comparing this
number with individuals’ actual working hours shows a divergence. Measured
against the welfare objective he has constructed, British workers with a relatively
low income work, on average, too little.
They could enhance their ‘well-being’
by working more hours each week. For
workers with a relatively high income,
the opposite holds: they work too many
hours each week, harming their own
‘well-being’. If the British government
would adopt and pursue this happinessbased welfare objective, it could increase
this welfare by reducing the marginal
income tax for low-income workers, and
raising the marginal income tax for highincome workers.
IV International Public Finance
Tax compliance, tax incidence and optimal taxation typically study the interaction between the private sector and the
public sector within a given regulatory
framework, whereas this framework can
be chosen by the government. Different
phenomena can be studied in the international context, when governments
themselves take the roles as players in
the international arena.
Standard problems that have for a long
time been studied in this context are the
choice of trade instruments, the theory
of optimal tariffs, tariff wars and strategic trade policy. Also, the theory of noncooperative collective action has major
applications in the international context.
These include the issue of international
public goods, such as international climate policy, international security and
the avoidance of international conflict
or war. A further important area in international public finance is the theory
of international taxation, international
tax competition and tax coordination in
a world with firms’ and other private sector decision makers’ cross-border transactions.
What differentiates many of these problems from standard problems in the
national context is a two-layered structure with strategic interaction between
governments in the top layer, and with
the absence of strong international institutions that could enforce international
contracts on this top layer. Recall the
theory of optimal tariffs, tariff unions
and tariff war: countries, or national
governments on their behalf, choose the
tariffs that apply for cross-border transactions. Once these decisions are made,
a regulatory framework exists in which
the private sector decision makers in different countries take this framework as a
given when making their own economic
decisions. Of course, the governments
anticipate this private sector behaviour
when making their regulatory/tax/tariff
choices. Furthermore, the policy choices
made in one country are interdependent with the policy choices made in an
other countries. Commitment between
countries is difficult to obtain as these
countries are souvereign. Further, policy
choice makers can be lobbied or influenced by important players from the private sector.
Research in international public finance
was conducted at the Department in the
reporting period in three broader areas:
(1) International Tax Competition and
Tax Havens, (2) Global Climate Change,
and (3) Fiscal Policy and Souvereign Debt
in the Eurozone.
1. Tax Competition and Tax Havens
Due to international mobility, increased
international trade and the internationalisation of business more generally,
taxation in one country increasingly has
fiscal spillovers to other countries and
redistributive effects between different
163
nation, surveys several dynamic aspects
and considers political economy aspects.
Conference on Understanding Tax Havens, 22–23 January 2014.
groups in the private sectors in different
countries. As a result, when countries
choose their tax rules, they take into
account that these rules have a crossborder impact. The strategic implications
of this insight have been assessed in a
large literature on tax competition and
tax coordination. Michael Keen and Kai
A. Konrad with “The theory of international tax competition and coordination”,
In: Auerbach, Alan J., Raj Chetty, Martin
Feldstein, and Emmanuel Saez (eds.)
Handbook of Public Economics 2012.
Amsterdam/Oxford: Elsevier, 257-328.)
survey the theoretical achievements in
this field. The survey addresses business
taxation in particular. It highlights the
early contributions, the Wilson-Wildasin-Zodrow-Mieszkowski model and the
Keen-Kanbur model of tax competition.
These are the two workhorse models
for theory on tax competition. It also addresses the role of full or partial coordi-
One intriguing phenomenon in international taxation is the emergence of what
is often called “tax havens”. These are
often described as small countries or
small jurisdictions within larger countries which seemingly operate a particular “business” model: they make use of
their national souvereignty or independence and offer special services to capital
owners and internationally operating
corporations. These services can take
various forms, but they typically allow
models of “tax optimisation” to operate
and include the provision of a decent local internal system of governance that
endows investors in this jurisdiction with
the amenities of a high level of security of property rights, and regulations
that offer the investor privacy vis-à-vis
the governments that may want to impose taxes on the capital or the returns
brought to the haven country.
Secret accounts, trusts or other legal entities with opaque ownership located in
these haven countries structure may be
used by private investors to shield own
capital returns from capital income taxation in their residence countries. Maybe
even more importantly, the haven countries are used for corporations to store
their international business returns for a
long time, delaying the corporate taxes
that may apply upon the repatriation
of these profits. Recently, several cases
discussed in the press reported US firms
reducing their effective corporate tax
burden close to zero, when they arrange
special deals with the local tax adminis-
tration of some countries, or firms that
delay the repatriation of profits and
simultaneously borrow large sums at
home to pay dividends to their shareholders. These reports have brought the
business of tax havens to the forefront of
the tax policy debate.
The characteristics of tax havens have
been studied more carefully in the last
10 to 15 years, and they have become
the main target of non-haven countries
and international non-governmental organisations, such as the OECD. However,
this research is just beginning. The nonhaven countries may rightly expect that
the existence of haven countries and
their tax sheltering business may erode
the basis for corporate taxation as far
as it is related to international corporations. And economists interested in the
distribution of income and wealth may
be concerned that such arrangements
protect the rich and very rich from income taxation and therefore may have
redistributive consequences that are
considered to be undesired or unfair,
or that the rich and wealthy cannot be
made accountable when it comes to the
allocation of the burden of financing
public expenditure.
May Elsayyad and Kai A. Konrad analysed the OECD’s strategy and process of
closing down tax havens from a dynamic
market theory perspective. This work is
published as “Fighting multiple tax havens” (Journal of International Economics 2012, 86(2), 295-305). This work was
discussed in the activty report of the
previous audit period. Their main concern is that a sequential closing down of
Figure taken from May Elsayyad and Kai
A. Konrad, “Fighting multiple tax havens”,
illustrating the game structures and the
role of sequential versus simultaneous
joint offers to deactivate several tax havens.
tax havens will increase the profitability
for the havens that remain in business.
Applying this insight for a back-of-the-envelope calculation, and using data from
Gabriel Zucman (“The missing wealth
of Nations: Evidence from Switzerland,
1914-2010”. Paris School of Economics
Working Paper No. 2011-07), they estimate that what it takes to convince the
last tax haven to quit is about twenty
times what it takes to convince the first
tax haven in this process, even if one assumes that the tax havens are, ex ante,
very similar. They also received indirect
support for the relevance of the competition between tax havens from the work
by Niels Johannesen and Gabriel Zucman
(“The end of bank secrecy? An evaluation of the G20 tax haven crackdown”.
American Economic Journal: Economic
165
Tim Stolper
Policy 2014, 6(1): 65-91). They show that
portfolio capital reacts to the number of
information transfer agreements signed
by a tax haven: some portfolio capital is
shifted away from these countries and to
other tax havens which were less active
in signing agreements.
In their working paper “Coordination and
the fight against tax havens”, Kai A. Konrad and Tim Stolper address the decision
of a haven country as to whether to give
in to international pressure and comply
with international standards of transparency or to resist the costly pressure and
maintain the secrecy regime typical for a
tax haven. This work complements the
work by May Elsayyad and Kai A. Konrad. It ignores competition between tax
havens, but highlights the importance of
small amounts of incomplete information. The haven country’s decision of
whether to offer services as a tax haven
is largely driven by the amount of costly
international pressure relative to the revenues that the haven can realise with the
tax haven business. The revenues depend
on the amount of investment that the
country can attract with its haven status.
These revenues, in turn are determined
endogenously by the individual decisions
of many individual investors who may
invest in the haven country or not. The
success or failure of the fight against tax
havens is the outcome of a many-player
coordination game. The analysis applies a
standard equilibrium selection tool from
the literature on coordination games,
the global game approach developed by
Carlsson and van Damme (“Global games
and equilibrium selection”. Econometrica
1993, 61(5), 989-1018) and Morris and
Shin (“Unique equilibrium in a model of
self-fulfilling currency attacks”. American
Economic Review 1998, 88(3), 587-597).
It derives a unique equilibrium for the
game. This equilibrium is then used to
derive a number of policy implications.
Uncertainty that is used in the theory
of global games as an equilibrium refinement concept is likely to be actually
present in the tax haven context. Hence,
one can make a more precise prediction
as to why some haven countries are very
successful in attracting large sources of
international investment and yielding
substantial profits, while other countries fail to do so. This work also shows
why the rents for tax havens are not
competed fully away despite the presence of multiple active tax havens and
international financial markets. Further,
the analysis has implications for the tax
policy of high-tax countries that went
largely unnoticed in the current policy
debate. There is a trade-off between a
successful fight against tax havens on the
one hand, and high tax rates in non-haven countries – e.g. in the context of an
international tax rate harmonisation – or
low fines for revealed offshore tax evasion – often implemented to encourage
the repatriation of offshore funds – on
the other side.
The tax haven phenomenon can also be
approached from an empirical perspective. May Elsayyad studied the empirical aspects of the tax havens’ reactions
to the OECD pressure. The recent G20
crackdown on tax havens has resulted
in a surge of new bilateral treaties that
regulate the information exchange between tax havens and high-tax countries.
Her work on this started in the previous
reporting period and was discussed in
the previous activity report. The main
contribution of her resulting paper entitled “Bargaining over tax information
exchange” is the analysis and identification of the main mechanism driving recent treaty signings by tax havens. The
analysis allows for a more detailed analysis of the legal vehicles proposed by the
OECD Harmful Tax Practices Initiative to
curb the tax haven phenomenon: the
signing of a TIEA or the inclusion of an
information exchange clause to a double
taxation convention (DTC). The paper
analyses the main factors determining
the signing of an agreement as the outcome of a bargaining process between
tax havens and high tax countries. Given
that a tax haven would rather sign an
information exchange treaty which also
facilitates cross-border investment (DTC)
than sign a treaty which only regulates
information exchange (TIEA), the paper
uses a stylised bargaining model to develop testable hypotheses with regards
to the type of agreement signed. The
theoretical model identifies the general
bargaining position of a tax haven versus
a high tax country, the effectiveness of
the defensive measures that can be used
by the high tax country against a tax
haven and the share of capital which is
evaded in the tax haven country as the
main drivers of the bargaining outcome.
Taking these insights to the data, she
argues that the respective bargaining
positions are a function of each country’s respective economic position, while
the effectiveness of the defensive measures is a function of the strength of the
bilateral relationship. Using an ordinal
maximum likelihood regression model,
the empirical analysis confirms that the
main drivers of treaty signing are havenspecific characteristics such as economic
strength and good governance. Bilateral
similarity and geographical proximity
characteristics seem to be unrelated to
treaty outcomes.
2. International Public Finance of
Climate Policy
The Department also continued its research on international public finance in
the area of climate policy. Among other
aspects, international climate policy
today is characterised by a preliminary
agreement of a subgroup of countries
(the Kyoto Protocol) and by an otherwise
non-cooperative framework between
countries with heterogeneous interests. A large community of researchers,
politicians groups, activists and other
interested parties has also emerged in
this context. A considerable group of
researchers and interest groups study
the problems of climate change. A long
167
series of climate summits documents
the difficulties and failures to reach an
international climate protection arrangement. The negotiating parties are
souvereign countries, and their number
is large. There is asymmetric information between the countries about the
actual objective functions of the politicians who negotiate with each other in
the climate summits, e.g. about their
willingness to pay for avoiding climate
change. Moreover, there is no global enforcement mechanism, no international
court to appeal to in case a country
does not stick to its agreements, and
no international power monopoly that
could enforce an international agreement or implement sanctions in case
of non-compliance by one or the other
country. This marks some of the difficulties in the process of reaching a climate
agreement. Today, even if an agreement
were to be reached in one of the next
meetings, it would not prevent, but only
limit climate change.
The National Academy of Science and
Engineering (acatech) has established a
working group named “Adaptation Strategies in Climate Policy”. Up to shortly
before the final publication stage, it was
chaired by Kai A. Konrad, Volker Mosbrugger (Senckenberg Gesellschaft für
Naturforschung und Universität Frankfurt) and Fritz Vahrenholt (RWE Innogy
GmbH). The report of this working group
that consisted of researchers and representatives of the different relevant industry branches, was published as “Anpassungsstrategien in der Klimapolitik”
in September 2012 as acatech’s position
paper to the climate change.
Position paper on climate change
from the acatech working group “Adaptation Strategies in Climate Policy”,
published September 2012.
Other policy relevant institutions have
also become interested in the topic of
adaptation. The European Investment
Bank prepared a public policy conference on climate policy for June 2012 and
commissioned a research paper to Kai
A. Konrad and Marcel Thum (Technische
Universität Dresden and ifo-Institute
Dresden) on the role of different layers
of the public sector for adaptation policy
in Germany and Europe. The paper entitled “The role of economic policy climate
change adaptation” was published in the
CESifo Economic Studies (2014, 60(1), 3261). The major results of this study have
already been adopted in the European
Investment Bank research report entitled “Investment and growth in the time
of climate change” (Atanas Kolev, ArminD. Riess, Georg Zachmann and Edward
Calthrop, Eds., Economic Department of
the EIB, Brussels) that appeared in 2012.
The paper highlights that adaptation is
largely a task that is carried out by the
private sector, and in private markets.
The report identifies only a few areas
in which public policy involvement in
adaptation policy is needed in Germany.
These mainly encompass the provision
of information, basic economic research
on climate change and climate change
adaptation, and a few areas in which regional public policy steps are desirable.
In her Ph.D. project, Sabine Aresin analyses the role of a special feature of climate
policy that was established as part of the
Kyoto Protocol. To facilitate compliance
with the protocol and to foster efficient
mitigation technologies in developing
countries and in emerging markets countries, industrialised countries have the
option to carry out abatement projects
abroad, in developing countries, with the
emission reductions generated by these
projects counting towards the industrialised countries’ achievement of their own
emission reduction goals. These crossborder abatement provisions are called
Clean Development Mechanism (CDM)
and allow industrial countries to abate at
the lowest possible cost, while promoting the recipient country’s know-how
in green technology and its economic
development. However, this mechanism
and the ability of some players to make
use of it also has strategic effects for the
emission abatement policies implemented by other countries. This makes the
equilibrium effects of such a mechanism
for total worldwide abatement and for
the allocation of the cost burden of these
abatement efforts less straightforward.
In the paper “Cross border abatement
and its welfare effects” (Max Planck Institute for Tax Law and Public Finance
Working Paper No. 2013-04), she analyses these effects in a non-cooperative
emission reduction game between two
countries. A key result is that the consequences of the CDM strongly depend on
“additionality”: whether CDM-projects
are low-cost abatement projects that
are substitutes for projects that could
also be carried out by firms or the government in the developing countries, or
whether the CDM leaves it to the developing countries to implement the lowcost-abatement projects themselves,
such that the CDM projects add to local
abatement. Only in the latter case will
developing countries abate at all. If,
however, CDM-projects crowd out projects which developing countries could
have taken on themselves, the emission
reductions generated by these CDM projects will merely become a substitute for
the emission reduction by the developing countries, which will cease to abate
at all.
Her current and future projects also focus on the CDM. In recent years several
emission trading schemes around the
world started to treat emission certificates generated abroad less favourably.
A given quantity of emission reduction
obtained abroad may then count for less
than the same quantity of emission reduction at home. She analyses how this
different weighing affects the equilibrium
choice of domestic and abroad abatement in her paper “Import restrictions
on emission credits”. A further project
is based on the idea that the difference
169
Sabine Aresin presents her findings at
the Workshop on Öffentliche Finanzen
und Politische Ökonomie, May 2013.
in regulatory treatment of abatement
at home and cross-border abatement
abroad may be related to information
asymmetries between the firms claiming
emission credits abroad and the national
governments. The well-known Crime and
Punishment framework dating back to
Gary Becker (“Crime and punishment: An
economic approach”. Journal of Political
Economy 1968, 76, 169-217) can be used
to explain why a government would like
firms to shift their emission abatement
away from abroad and towards domestic
abatement, if such information asymmetries exist.
The project entitled “Technology transfers for climate change” by May Elsayyad
and Florian Morath (2013) is motivated
by the recent success of international
initiatives for the transfer of green
technology as an instrument to tackle
the problem of climate change. They
develop a dynamic model which adds
another important trade-off to the clas-
sic public goods problem. Countries face
the following trade-off when deciding
on their contribution to climate protection: decision-makers have an incentive
to wait until (some of) the uncertainty
about the impact of climate change on
the country level is resolved. But delaying action may also turn out to be costly
due to the concentration of greenhouse
gas emissions in the atmosphere, which
makes current emissions (and foregone
emission reduction efforts, respectively)
basically irreversible. Incentives to freeride not only on other countries’ current
climate protection effort but also on their
future efforts will bias the countries’
contribution path towards later contributions. They also show that the transfer/export of cost-reducing technology
to other countries affects the trade-off
between uncertainty about the impact
of climate change and the irreversibility
of foregone climate protection efforts;
hence, technology transfer affects the
countries’ timing of their contributions.
Even though advanced green technology
makes it generally cheaper to contribute to climate protection, technology
transfer can make it relatively more expensive to delay action against climate
change. By inducing other countries not
to delay their climate protection efforts,
the transfer of green technology can be
strategically beneficial for the country
that has developed the technology. Effects pointing in the opposite direction
are also possible when countries share
technology that is particularly useful
in the future and thereby strengthen
other countries’ incentives for delay;
sharing such types of technology would,
however, be strategically disadvanta-
geous for a country. Technology transfer
mechanisms are shown to have positive
welfare effects whenever they induce
countries to shift their contributions to
climate protection to an earlier point in
time, and their implementation can be
the outcome of a non-cooperative game,
making these mechanisms particularly
promising policy instruments.
Theory work in the Department on the
role of incomplete information in the
context of international climate negotiations reconsiders work by Michael Hoel
(“Global environmental problems – The
effects of unilateral actions taken by one
country”. Journal of Environmental Economics and Management 1991, 20(1),
55-70) on unilateral commitment. He established that a policy in which one country takes a lead and unilaterally commits
to making high efforts in own national
emission reductions is mainly counteracted by increases in the emission levels
that will be chosen in other countries. In
the complete information context he considers, the unilateral commitment does
not affect the probability of reaching an
international environmental agreement.
As an application of the Coase theorem,
reaching a cooperative agreement can
be taken for granted in this framework.
The work by Kai A. Konrad and Marcel
Thum (Technische Universität Dresden
and ifo-Institute Dresden) that has already been mentioned in the previous
activity report researches the role of
unilateral commitment for the likelihood
of reaching a climate agreement if the
negotiating politicians who meet in the
world climate summits have incomplete
information about their mutual eager-
ness to reach such an agreement. Using
a bargaining framework with incomplete
information, they show that unilateral
leadership typically reduces the likelihood of an efficient agreement. This
work is published as “Climate policy negotiations with incomplete information”
(Economica 2014, 81(322), 244-256).
The same authors also apply a similar
logic to other aspects of international
climate policy. They show that the availability of transborder emission abatement that can be used by countries to
fulfill their own abatement goals, such as
a Clean Development Mechanism (CDM)
in the Kyoto Protocol has a similarly negative effect for the likelihood of reaching
a cooperative climate agreement. This
result is described in a paper entitled
“Does a clean development mechanism
facilitate international environmental
agreements?” (Max Planck Institute for
Tax Law and Public Finance Working
Paper No. 2014-20). While the precise
mechanism at work and the policy question addressed differ from the previous
research result, the logic is similar to
the bargaining framework on unilateral
commitment. The more general principle
that applies is known as the topsy-turvy
principle in industrial organisation: cooperation becomes more difficult if the outcome of non-cooperation is less harmful
for the potentially cooperating players.
3. Souvereign Debt and the Eurozone
A further issue in international public finance, and one that has received utmost
policy prominence in recent years, is the
171
problem of souvereign debt inside the
European Monetary Union. This topic
was already on the agenda of the activity report in the period 2010–2011 and
some of the policy-focussed research
in the Public Finance Department was
geared towards this topic.
In short, after a long period of interest
rate convergence inside the Eurozone,
the revision of the Greek government
deficit from about 3 per cent to close to
14 per cent of the GDP marked the end of
this period and led to the first souvereign
debt crisis inside the Eurozone. This crisis
did not trigger a default and restructuring, as would have been suggested by
the “no bailout” Article 125 (AEUV). The
crisis spread towards other member
countries. This spreading had different
reasons in the varous crisis countries, but
all reasons were related to the financial
and economic crisis that had emerged
in 2007 and the impact the crisis had on
some policy developments in the respective countries that were unhealthy, but
remained without major negative consequences in the boom time prior to the
crisis. With the first half of 2010 the Eurozone entered into a muddling-through
regime which is still ongoing. Major steps
in this process were the attempt to revise and revitalise the European Stability and Growth Pact, intergovernmental
guarantees such as the early guarantee
devices that were followed and replaced
by the ESM, and interventions by the
European Central Bank, with the LongTerm-Refinancing Operations, the Outright Monetary Transactions programme
(OMT) and the announcement of a major
programme of Quantitative Easing.
Members of the Department contributed
to the policy debate along several channels. Kai A. Konrad and Holger Zschäpitz
(financial journalist at “Die Welt”) published the first book on the European
debt crisis in Germany in 2010 (see ac-
Kai A. Konrad
Holger Zschäpitz
Schulden
ohne Sühne?
Was Europas Krise uns
Bürger kostet.
dtv Verlag
283 p.
tivity report 2010–2011). The book
gained major public attention and was
nominated for the “Wirtschaftsbuchpreis” in 2010. A thoroughly revised and
updated edition of this book was entitled
“Schulden ohne Sühne? Was Europas
Krise uns Bürger kostet” and was published as a paperback edition (dtv-Verlag,
2012) two years later. It offers an analysis
of the various mistaken developments
that eventually led to the European Debt
Crisis, offers an assessment of the early
measures taken to address the crisis, and
sketches an alternative approach to deal
with the crisis. In commentaries and interviews in newspapers and in short articles in policy outlets such as vox.org, oekonomenstimme.org, Ifo-Schnelldienst,
Wirtschaftsdienst, among other outlets)
Kai A. Konrad also commented on the
developments in the course of the crisis.
As the Chairman of the Council of Scien-
tific Advisors to the Federal Ministry of
Finance he also contributed to several
statements of this group on this topic.
The Council also completed a detailed
report on the European financial crisis
in January 2012 and this document was
formally handed over to the Minister on
2 March 2012. This report characterises
the current reform process as a combination of rescue activities that collectivise
debt responsibility inside the European
Union, and changes in the governance
structure that shift more control rights
from the nation states to the European
governance level.
The Council report provides economic
and political reasons as to why a policy
that aims at an improved Stability and
Growth Pact is likely to fail in the medium
run and why this policy risks breaking up
the European Union. The Council report
also provides advice as to what would be
an alternative, sustainable governance
regime that is organised along the principles of autonomy and national respon-
173
sibility, what is the specific role of reform
in the banking sector and in the regulation of financial markets for making this
regime credible, and how the transition
from the status quo to this regime could
be achieved.
tral Bank is stretching its mandate by too
much. The court will need to come to a
ruling once the European Court of Justice
has provided its own assessment.
In 2013 the German Constitutional
Court (Bundesverfassungsgericht) had
an expert hearing on the Outright Monetary Transactions (OMT) programme of
the European Central Bank. The court
basically had to rule on whether the
European contract of Maastricht that established the common currency area in
Europe and the European System of Central Banks is compatible with the German
constitution, given that the European
Central Bank adopts the OMT. Evidently,
the German Constitutional Court has no
direct jurisdiction regarding the European Central Bank, and the question it
has to decide addresses the behaviour
of German governmental institutions in
particular. Kai A. Konrad was appointed
as one of the expert witnesses to the
Court and offered his assessment to the
court at the court meeting in June 2013.
V Political Economy of Distribution
and Conflict
All five independent economist witnesses’ statements (Clemens Fuest, Marcel
Fratzscher, Kai A. Konrad, Hans-Werner
Sinn, Harald Uhlig) were published in a
collected volume entitled “Bundesverfassungsgericht und Krisenpolitik der
EZB – Stellungnahmen der Ökonomen”,
(Wirtschaftsdienst 2013, 93(7), 431454). The final court ruling is still not out
at the time of this report’s production,
but the court has already declared that
it is likely to consider the OMT program
as an action by which the European Cen-
Research on the public sector should
not overlook major insights of political
economy: politicians are self-interested
decision makers who optimise within
the constraints of the political system. In
an ideal world the contractual arrangement in which these choices are made
perfectly aligns their objectives with the
objectives of a greater public, the representative citizen, their constituency, or
the well-understood common interest.
But in a world with collective decision
making, with conflicting interests, with
bureaucrats, experts, interest groups
and policy makers, with information
asymmetries, with transaction costs and
with problems of time consistency and
commitment, the policy process is less
straightforward, and also more interesting from a research perspective.
The area of “Political Economy of Distribution and Conflict” takes these aspects
on board. While many studies in the
other programme areas consider principal-agent problems by which the (wellminded) government faces a private sector who reacts to what the government
chooses, or in which the government is
confronted with other governments in
other countries, and acts on behalf of
the well-understood interest of its own
constituency, this section also studies
the process that leads to governmental
decision making.
1. Conflict Theory
Part of this research is carried out in a
sub-project on “Conflict in Governance
Problems” within the Sonderforschungsbereich (SFB) TR-15. This SFB is entitled Governance and the Efficiency of
Economic Systems and brings together
about 15 different projects based in
Bonn, Berlin, Mannheim and Munich
and is funded by the German Research
Foundation (DFG) and started its third
funding period (2012–2015) at the beginning of the reporting period in this
activity report. The purpose of the subproject in the first two funding periods
was to study the role of resource-wasteful conflict as an empirically relevant
determinant of allocation processes. The
third funding period is about the role of
collective action, and in particular, the
role of alliances in this context. Representative of this agenda are research
questions stated in the research outline,
such as: how does the existence of an
alliance or the nature of its formation affect the ability and willingness of players
to mobilise resources for conflict? How
does a common history as “brothers in
arms” or a common history as having
interacted in more antagonistic roles affect distributional conflict and any possible struggle about resources among
players? When do alliances form, and
when do they break up? What is the role
of information for the formation or erosion of alliances? What is the role of the
Workshop on Contest Theory and Political Competition, 4–5 September 2014.
governance structure inside an alliance
for success? These are most fundamental questions and some of these questions have been taken up in the context
of economics and political science. The
research methodology is the formation
of theory and theory-guided controlled
laboratory experiments.
In a series of laboratory experiments,
Changxia Ke, Kai A. Konrad, and Florian
Morath investigate the role of internal
distributional conflict for the prospects
of alliances. In the paper “Brothers in
arms – An experiment on the alliance
puzzle” (Games and Economic Behavior
2013, 77(1), 61-76) they analyse how the
possibility of internal conflict affects the
willingness of alliance members to contribute to the alliance effort. Does future
distributional conflict inside a victorious
alliance discourage its members from
making effort contributions in the conflict between the alliance and its adversary, compared to a situation in which alliance members can commit to share the
175
spoils of victory peacefully? In line with
the theoretical prediction, the experimental evidence confirms such a hold-up
effect, which leads to lower effort contributions when alliance members anticipate future internal conflict. Nevertheless, independent of the process of prize
allocation in victorious alliances, the
free-riding of alliance members is less
pronounced than predicted by a theory
of narrowly selfish players. This finding is
in line with aspects like in-group solidarity and in-group favouritism, which have
been argued to be particularly strong in
the presence of an out-group.
The study also asks whether such ingroup favouritism survives the end and
break-down of an existing alliance. How
do the alliance members’ experiences
of successfully fighting ‘shoulder-toshoulder’ affect their willingness to turn
against each other when they have to
solve the distributional conflict between
them? By comparing the efforts of alliance members in an internal distributional contest to the efforts of players who
do not have any joint history, they find
that within their institutional environment, in-group solidarity breaks down
as soon as the joint enemy is defeated;
former allies fight each other even more
vigorously than contestants who do not
have a joint history.
In another set of experiments this group
of authors (“Alliances in the shadow of
conflict”. Economic Inquiry, forthcoming)
analyses the determinants of whether
internal distributional conflict emerges
within victorious alliances when alliance
members cannot commit ex ante to a
prize-sharing rule. In the experiments alliance members have to choose whether
to share the prize peacefully or whether
to enter into distributional conflict once
they have defeated the joint adversary.
The focus is on two main institutional
variations: asymmetries, and non-binding announcements. First, an imbalance
between the alliance members’ fighting
strength in the internal conflict and the
rent distribution in case of a peaceful
settlement matters for the likelihood of
internal conflict. Players are more likely
to fight internally the more unequal the
division of the prize is, even if the peaceful settlement yields a higher material
payoff to both alliance players. In turn,
the higher likelihood of internal conflict
is anticipated by alliance members and
strengthens the hold-up problem when
fighting the out-group. Second, alliance
members may make use of (non-binding)
ex-ante declarations on their prize-sharing intention. In line with the prediction
for payoff-maximising players, the opportunity to make non-binding declarations does not change either the actual
probability of internal fight or the effort
contributions of alliance players in the
conflict with the out-group, compared to
a situation where ex-ante non-aggression
declarations are not possible. Finally, the
experimental results show that internal
conflict becomes more likely−and more
intense−the more unequally the alliance
members have contributed to the fight
against the joint enemy.
Kai A. Konrad and Florian Morath (“Evolutionary determinants of war”. Defence
and Peace Economics, forthcoming) provide a theoretical underpinning of the
observation that players may choose to
fight even if this reduces their monetary
payoff. They study evolutionary arguments in the context of finite populations. If players’ strategies are shaped by
evolutionary forces in small populations,
this puts an emphasis on relative rather
than absolute material payoff. Consequently, players may reject resource allocations and trigger distributional conflict even when conflict leads to a lower
material payoff, as long as conflict makes
them better off in relative terms. They
show that the range of peaceful resource
allocations that is evolutionarily stable is
smaller than the corresponding range in
the subgame perfect Nash equilibrium.
Besides the moral hazard problem within
alliances and the hold-up problem generated by the potential of internal conflict,
the work entitled “Endogenous group
formation in experimental contests” by
Luisa Herbst, Kai A. Konrad, and Florian
Morath (European Economic Review,
forthcoming) focusses on a third important aspect of alliance formation: the
self-selection of certain types of players
into alliances. While endogenous alliance formation may also strengthen
aspects like in-group solidarity and
in-group favouritism in comparison to
exogenously formed alliances, adverse
selection can constitute a major problem when alliances are formed on a
voluntary basis. Taking into account that
individuals may differ in their intrinsic
or extrinsic incentives to expend effort,
the theory analysis predicts that such
heterogeneity leads to a self-selection of
weakly motivated players into alliances
while strongly motivated players prefer
Figure taken from Kai A. Konrad and Florian Morath, “Evolutionary determinants
of war”: The range of peaceful resource
allocations that is evolutionarily stable is
smaller than the corresponding range in
the subgame perfect Nash equilibrium.
to stand alone in an upcoming conflict.
The intuitive reason is that strong players
bear a disproportionately high share of
the cost of alliance effort and therefore
prefer to stand alone, while weak players
benefit from the free-riding opportunities inside alliances.
The theory prediction is confirmed in the
experimental treatments. In particular,
the experimental results show that selfselection occurs along heterogeneity in
both intrinsic and extrinsic motivations.
Players who have a low monetary and/
or non-monetary cost (“strong players”)
of expending effort select predominantly
into stand-alone contests, while players
with a high monetary and/or non-monetary effort cost (“weak players”) enter into
endogenously formed alliances. While
177
lead to a higher level of fighting effort
than in the Nash equilibrium for players
who maximise their material payoff. In
contrast to previous results, the evolutionary foundation for in-group altruism
and out-group spite is not based on the
observability of preference types with
the implied strategic behavioural effects
but is derived in a framework with strict
private information on individuals’ types.
Figure taken from Luisa Herbst, Kai A. Konrad, and Florian Morath, “Endogeneous
group formation in experimental contests”: It symbolises the generic question
of alliance formation of players who enter
into conflict either as stand-alone players
or as an alliance of players.”
the self-selection of weak players leads
to lower effort in endogenously formed
alliances, the evidence found suggests
that there is also an effort-stimulating
effect if players endogenously form an
alliance, which is in line with theories of
in-group favouritism and which partially
counterbalances the negative effect of
self-selection.
An evolutionary explanation for the emergence of in-group favoritism is provided
by Konrad and Morath (“Evolutionarily
stable in-group favoritism and outgroup
spite in intergroup conflict”. Journal of
Theoretical Biology 2012, 306, 61-67).
This work focusses on a framework in
which groups fight with each other. They
show that the emergence of altruism
towards the members of the own group
and of spiteful attitudes towards the
members of other groups is evolutionarily stable. In fact, in-group altruism and
out-group spite are substitutes and both
A related question on evolutionarily stable behaviour in distributional conflict is
analysed by Konrad and Morath (“Bargaining with incomplete information:
Evolutionary stability in finite populations”. Max Planck Institute for Tax Law
and Public Finance Working Paper No.
2014-16). While incomplete information
is known to cause resource allocations
in bargaining games to be inefficient,
this work considers how the outcome of
bargaining games with incomplete information changes if players who bargain
pursue evolutionarily stable strategies.
Their main model focusses on a take-itor-leave-it offer bargaining game with a
responder who has private information
but the analysis is also extended to the
case of a privately informed proposer.
For evolutionarily stable strategies, the
parameter range in which trade takes
place turns out to be more limited than
for perfect Bayesian equilibrium. The
main intuition for this low-trade result is
that responders reject offers that would
increase their own material payoff but
would make them worse off relative to
the rest of the population. The same
concerns for relative payoff, however,
cause the proposer to accommodate
to the anticipated responder behaviour
and to make a more generous offer.
Evolutionary considerations hence make
the responder look ‘aggressive’ and the
proposer look ‘accommodating’. The
overall effect for the probability for trade
is negative. The accommodating behaviour is not sufficient to overcome the primary, efficiency-reducing effect of tough
responder behaviour.
By and large, these theory results suggest that institutional environments in
which concerns for relative payoffs become more important can have severe
consequences for distributional conflict
and efficiency; accordingly, defining and
enforcing property rights becomes more
valuable in these environments.
Contests between alliances can follow
a variety of rules. The most common
assumption is that the members of an
alliance pool effort, each group making
the best out of the resulting budgets,
like military alliances may do. But as analysed by Qiang Fu, Jingfeng Lu, and Yue
Pan in their recent work entitled “Team
contests with multiple pairwise battles”
(forthcoming in American Economic Review), a different structure may apply:
the members of two rival alliances may
compete on a one-by-one basis in component contests with their individual
counterpart, and victory may be a function of the number of victories in such
component contests. In a paper titled
“’Success breeds success’ or ‘Pride goes
before a fall’? Teams and individuals in
multi-battle contests” (under invited revision and resubmission to Games and
Economic Behavior), Qiang Fu, Changxia
Ke, and Fangfang Tan offer the first
empirical evidence from a controlled
laboratory experiment on the impact of
progress feedback in such group contests
with one-by-one component contests.
Their findings suggest that the impact
of progress feedback also depends on
the contest structure. The same feedback mechanism could affect a player’s
performance and incentives differently
according to whether the production is
team-based or individual-based.
Some further work in this area was
described in the activity report for the
previous period, but has been finalised
and published in the current activity
period. Kai A. Konrad and Dan Kovenock
analyse contestants who can self-select
themselves into one of a set of different
tournaments or contests. They study
the problem of coordination of players
as regards the self-selection into tournaments. The problem has a large number
of equilibria with very different welfare
properties. Outcomes and equilibrium
payoffs strongly depend on whether
players can coordinate or not. Their paper “The lifeboat problem”, published in
the European Economic Review (2012,
56(3), 552-559), provides a characterisation of how and when certain classes of
uncoordinated equilibrium yield superior outcomes for the contestants than
classes of coordinated equilibrium. A
further paper by Kai A. Konrad entitled
“Information alliances in contests with
budget limits” in Public Choice (2012,
151(3-4), 679-693) studies the role of
information exchange for whether an
alliance is formed. We reported about
this work in more detail in the previous
activity report. Information transmission
179
is easier and more likely to occur inside
an alliance than between non-allied
players or across different alliances.
Members of the same alliance may learn
about the strengths and weaknesses of
other members of the same alliance.
There are many reasons why this improved knowledge could be mutually
useful, even if the members of such an
alliance do not pool resources or fight
jointly. The paper studies one particular
type of information: the fighting power
of the co-members of the alliance. It is
shown that transfer of this information
is a powerful reason for why an alliance
may be formed. Finally, work by Kai A.
Konrad and Stergios Skaperdas which we
also described in more detail previously,
entitled “The market for protection and
the origin of the state”, was published in
Economic Theory (2012 (50(2), 417-443).
2. Electoral Competition
Motivated by the developments and
repercussions of the “Arab spring”, May
Elsayyad and Shima’a Hanafy (PhilippsUniversity Marburg) studied the early
elections after the revolution in Egypt.
Their paper entitled “Voting Islamist or
voting secular? An empirical analysis of
voting outcomes in Egypt’s ‘Arab spring’”
(Public Choice, 2014, 160(1-2), 109-130)
empirically analyses the voting outcomes
of the first parliamentary elections in
post-revolution Egypt along one particular dimension: the secular versus Islamist spectrum. With the central theme of
the elections focussing on the drafting of
the new constitution, both old and new
parties positioned themselves along the
May Elsayyad
secular-Islamist dimension in an attempt
to shape Egypt’s future political identity.
Using a unique dataset of voting outcomes from the country’s 2011–2012
parliamentary elections at the constituency level and the most recent population and housing census data, their crosssectional analysis identifies two dimensions that affected voting outcomes: the
socioeconomic profile of a constituency
and the institutional framework of the
voting procedure. Specifically, the analysis shows that education seems to be a
strong and robust predictor of secular
or Islamist voting. A larger share of university graduates in a constituency is significantly correlated with a larger share
of secular voting and a smaller share of
Islamist voting. Furthermore, illiteracy
has a significant positive correlation with
the share of voting for Islamist parties.
A particularly important result of this
analysis pertains to the effect of poverty
on voting outcomes. Interestingly, when
controlling for education levels, higher
poverty levels do not correspond to larger
shares of voting for Islamist parties. In fact,
more poverty is associated with fewer
votes for Islamist parties. This is particularly
surprising given the strong social outreach
character of Islamist groups.
This analysis further confirms the notion
that the sequential voting framework and
the timing of elections affect voting outcomes. In fact, voters showed significantly less support for the winning Islamist
parties in the last stage of the vote. Thus,
this research finds no evidence of a bandwagon effect. This finding supports the
argument that voters in the later stages
opted to vote strategically so as to ensure
diversity in the elected parliament.
Erik Hornung considers empirically the
Political Economy of Parliamentary Voting in Prussia. A major step towards
redistribution was undertaken with the
introduction of the Prussian parliament
after the German Revolution of 1848. The
established voting rights were however
far from equal; the particular three-class
franchise system in Prussia disadvantaged median voters and led to an overrepresentation of the upper and middle
classes. A project by Erik Hornung and
Sascha Becker (University of Warwick)
analyses the outcome of voting by roll
call by members of the Prussian House of
Representatives (MP). The project is not
completed. Hypotheses that emerge and
preliminary findings can be described as
follows.
It is likely that due to the particularity
of the three-class franchise system, the
MPs’ interest was more aligned with the
upper class of their constituency than
with the interest of the median voter.
Consequently, roll call voting of MPs
might be supportive of elite interest and
preventive of redistributive reforms.
Combining new data on individual-level
votes from parliamentary minutes with
biographical information of representatives and constituency-level information,
the project team predicts the voting
behaviour of delegates during a range of
historically important ballots in the Prussian Parliament during the period 1867
to 1908. Their estimates analyse the
driving forces of the Prussian political
economy during a period of fundamental
changes from agriculture to capitalism,
from liberalism to protectionism, from
an ecclesiastical to a secularised economy, and from poll taxation to income
taxation. Preliminary findings suggest
that delegates often vote in their own
self-interest and disregard the median
voters in their constituency.
3. Intergovernmental Bargaining
Alongside more resource-wasteful conflict or electoral competition, political
bargaining between parties is another
important element of political decision
making that aims to resolve distributional conflict. A joint research project
of Thomas R. Cusack at the WZB Berlin
Social Science Center and Kai A. Konrad
analyses how the formation of groups
of political players and the unanimity of
decision making may affect bargaining
outcomes. Such groups may be formed
inside a country, but the prototypical
example for these groups is intergovernmental arrangements such as the
European Union. The researchers ask:
What is the strategic role of the forma-
181
tion of an intergovernmental group with
unanimity requirements if the members
of this group negotiate with an outside
player in a setting with incomplete information? The finding is that the formation of this group with veto players has
two main effects. First, the formation
of a joint decision mechanism in which
each member of the group has veto
power typically shifts bargaining power
towards the members of this group. The
key mechanism that benefits the group
is a strategic effect of the unanimity requirement as regards the behaviour of
the outside player. The veto power that
each member of the group has as regards
a possible negotiation outcome tends to
reduce the ex-ante probability of bargaining success. This makes the outside
player less demanding in the negotiations and makes him willing to settle for
less. Second, the unanimity requirement
causes the group to reject possible negotiation outcomes unless all players
are satisfied with the outcome. This is a
potential source of inefficiency. The expected overall efficiency of the negotiation outcome tends to be lower than in
the case of separate, bilateral bargaining.
The unanimity requirement implies that
partial bargaining success, in which one
of the group members likes the deal very
much but the other group member does
not, is prevented: deals made by the outside player with only one members of the
intergovernmental group cannot emerge,
even if such a deal would be highly beneficial to both of them. The size and importance of the efficiency loss depends
on the internal governance structure of
the group, and the efficiency loss can be
moderated if side payments can be ar-
ranged inside the group. The aspect of
incomplete information evidently plays
a major role here. Incomplete information is the source of potential inefficiency,
where an agreement is not reached even
though it would be mutually beneficial.
Under complete information this could,
of course, not happen and the negotiation
outcome would be efficient in any case in
the environment we study as the Coase
theorem would apply. The project goes
further and studies more precisely the
role of preference alignment and preference independence among the members
of the intergovernmental group and the
role of side payments. The conclusion is
that the joint distribution from which the
specific preferences of the members inside the group are randomly chosen matters. For a wide parameter range for this
joint distribution, small coalition groups
with unanimity requirements tend to
achieve better outcomes for its members,
compared to fully decentralised, bilateral
negotiations.
The main results from this project are
published as “Hanging together or
hanged separately: The strategic power of
coalitions where bargaining occurs with
incomplete information” (Journal of Conflict Resolution, 2014, 58(5), 920-940).
4. Property Rights Allocation and its
Effects on Growth and
Development
The allocation of property rights and
decision rights is known to be essential
for economic outcomes as well as for development and economic growth. One of
the most important historical changes in
property rights was the abolition of serfdom. The abolition of serfdom assigned
the property rights to labour for a large
fraction of the population in Germany
at the beginning of the 19th century.
Formerly coerced peasants were now
able to reap the benefits of their own
labour and investments. A range of projects undertaken at the MPI empirically
analyse which circumstances led to the
introduction of such changes and what
consequences derive from this change in
the property rights regime.
Cooperating with a range of international
researchers, Erik Hornung (and Quamrul
Ashraf, Williams College; Francesco Cinnirella, ifo-Institute; Oded Galor, Brown
University; Boris Gershman, American
University) analyse the abolition of serfdom theoretically as well as empirically.
They argue that the abolition of serfdom
occurs as a strategic decision of the elite
to increase their income. Under serfdom,
the return to labour is effectively unprotected for a large part of the population. Since the political power is entirely
owned by the economic elite, they are
able to choose the amount of labour coercion that they want to extract from the
serfs. The model predicts that there exists
a capital-labour ratio where it becomes
beneficial for the owners of physical capital to increase the share of human capital
in the production process. However, due
to the lack in incentives to invest, the
supply of human capital from the serfs is
insufficient. This means, the elite need to
change the incentives for investment in
human capital. The elite chose to either
continue expropriation or to abolish the
Figure taken from the work of Erik Hornung et al.: Share of serfs emancipated
from labour services in 1848.
coercion of serf-labour and guarantee the
protection of property rights. The model
suggests that this change happens when
a certain capital-labour ratio is reached.
This is the point where the elite’s income
from abolishing serfdom exceeds their
income from coercion.
Using unique new data on the redemption of coerced labour services from 19th
century Prussia, the project team found
empirical evidence supporting the predictions of the theoretical model: Emancipation from serfdom occurs earlier in
regions with an initially larger stock of
physical capital. Furthermore, they evidence – consistent with the hypothesis
– that regions where coercion was ended
comparatively early thus introducing
effective property rights, subsequently
exhibit a higher level of mass education.
These findings find further support in
a second project by Erik Hornung and
183
Francesco Cinnirella (ifo-Institute). According to the literature, elites generally
oppose redistribution using their political power to i.e. block the extension of
voting rights or the expansion of school
financing for mass education. In a recent article, the researchers propose
an alternative mechanism based on the
labour relations between the elite and
the masses. Due to the prevailing institutions of serfdom, the nobility exercised
a direct authority over the local population by performing the functions of policing and jurisdiction as well as patronage
over churches and schools. Their unique
position of power allowed the nobility
to directly interfere with the education
decisions of the peasantry. Using a large
panel dataset including unique data on
land distribution and school enrollment
rates spanning the entire 19th century,
Cinnirella and Hornung analyse the relationship between feudal power as measure by landownership concentration and
peasants’ investments in education. They
show that a large regional concentration
of noble landowners is associated with
lower enrollment rates in mass primary
schooling. Furthermore, findings suggest
that due to the introduction of agricultural reforms that eroded the authority
of noble landowners, peasants gradually
emancipated from labour coercion and
increasingly enrolled in primary schools.
Throughout the 19th century, the negative effect of the nobility on education
decreases. Further findings indicate that
the nobility did not limit the provision of
public schooling by restricting the supply
of teachers and schools. This supports
the hypothesis that the nobility restricted the demand for schooling through the
coercion of labour services that prevailed
even after serfdom was formally ended.
A second aspect of public investment in
human capital is the provision of health
care. The introduction of compulsory
health insurance, advocated by the
chancellor of the German Reich Otto von
Bismarck and the Parliament as part of
the so-called Bismarck reforms was an
important step towards social protection
and redistribution. The recent introduction of the Affordable Care Act (“Obamacare”) in the U.S. is an important example
for the ongoing debate regarding consequences of mandatory health insurance
for the economy. Erik Hornung, Anastasia
Driva (LMU Munich), and Stefan Bauernschuster (University of Passau) analyse
the first-ever occurrence of compulsory
health insurance that took place in 19th
century Germany. The project analyses
the causal link between the provision of
compulsory health insurance and mortality in Prussia, the largest of the German states. The empirical strategy rests
on the fact that the compulsory nature
of the health insurance only applied to
industrial workers. This allows us to define a clear treatment group (the industrial workers) and a clear control group
(the agricultural workers). Preliminary
findings suggest that a relative increase
of the insured is associated with a strong
decrease in mortality, even after controlling for a range of indicators for overall
industrialisation, development, income
and changes in sanitation and pollution.
Next to the provision of public goods in
the form of schooling and health care,
public infrastructure is an important as-
pect of development. Investments in public transport infrastructure, in particular,
are a matter of debate whenever governments are in need to boost the economy
during downturns in the business cycle.
The study “Railroads and growth in Prussia” by Erik Hornung that was accepted
for publication in the Journal of the European Economic Association sheds light
on the relationship between investment
in railroad infrastructure and subsequent
growth. Cities that gained railroad access
in the early phase of railroad-network
expansion in Prussia subsequently grew
an additional 1.7 percentage points faster than their unconnected neighbours.
One of the main challenges in the assessment of the benefits from investing
in transport infrastructure is separating
the part of growth that is induced by
the infrastructure itself, from growth
that would have occurred anyway due to
fundamental characteristics of cities that
gained access. The author combines data
on the expansion of the railroad network
derived from geoinformation systems
with historical data on the expansion of
roughly 1,000 cities in terms of population growth and industrial growth. The
use of geoinformation allows us to establish a quasi-random assignment of
railroad access to quantify the causal effect of railroad access on urban population growth. Cities located on a straight
line between two major cities were more
likely to gain access to the railroad than
cities that deviated from the straight line
but were otherwise similar. Fortunately,
highly detailed census data allow a comparison only among those cities that
were similar in their size and economic
development prior to the coming of the
For his work, Erik Hornung, along with
a group of researchers, digitised and
organised data that the Royal Prussian Statistical Office collected over the
period 1816–1901. He digitised around
1 million of the historical material’s
data fields. First, the original sources
were photographed and then the data
was transferred manually into spreadsheets. The result is a huge archive, the
Ifo Prussian Economic History Database
(iPEHD). Picture: Royal Statistical Bureau (1873), Volume VIII, pp. 234-235.
railroad and thus only differed regarding
their initial access to the railroad. The
subsequent additional growth of these
cities can hence be attributed to investment in public transport infrastructure.
VI Perspectives for the Future
Most of the research lines of this reporting period are very active at the end of
the period and stretch into the next reporting period. These include, in particular, the theory and experimental work on
185
Staff Retreat, July 2012.
tax compliance, the work on understanding international taxation and tax havens,
and the work in the area of political
economy of redistributive conflict. Some
of the work is at an intermediate stage,
where the first research results are documented in the format of a manuscript or
a working paper, waiting for the process
of publication. This process often requires much further work, revisions and
additional treatments in experiments.
We look forward to report about the results in three years from now.
B Publications, Lectures, Teaching, and
Awards
IPublications
Sabine Aresin
Discussion Papers
Aresin, Sabine. 2013. “Cross border abatement and its welfare effects.” Working Paper
Becker, Johannes and Nadja Dwenger.
2013. “Die Besteuerung von Fremd- und
Eigenkapital aus ökonomischer Sicht.” In:
Schön, Wolfgang (ed.), Eigenkapital und
Fremdkapital. Steuerrecht, Gesellschaftsrecht, Rechtsvergleich, Rechtspolitik. Berlin/
Heidelberg: Springer, 101-124.
Discussion Papers
Johannes Becker
Journal Articles
Becker, Johannes and Marco Runkel. 2012.
“Even small trade costs restore efficiency in
tax competition”. Journal of Urban Economics, 72(2-3), 191-195.
Becker, Johannes, May Elsayyad, and
Clemens Fuest. 2012. “Die Auswirkung der
Globalisierung auf die Struktur der Besteuerung”. Perspektiven der Wirtschaftspolitik,
13(1-2), 4-18.
Becker, Johannes. 2013. “Taxation of foreign
profits with heterogeneous multinational
firms”. World Economy, 36(1), 76-92.
Becker, Johannes and Nadine Riedel. 2013.
“Multinational firms mitigate tax competition”. Economics Letters, 118(2), 404-406.
Becker, Johannes and Marco Runkel. 2013.
“Corporate tax regime and international
allocation of ownership”. Regional Science
and Urban Economics, 43(1), 8-15.
Bronsert, Anne-Kathrin, Amihai Glazer,
and Kai A. Konrad. 2014. “Old money, the
nouveaux riches and Brunhilde’s marriage strategy”. Working Paper of the Max
Finance No. 2014-15 (http://ssrn.com/abstract=2476388) and IZA DP No. 8307.
Nadja Dwenger
Journal Articles
Dwenger, Nadja and Viktor Steiner. 2012.
“Profit taxation and the elasticity of the
corporate income tax base. Evidence from
German corporate tax return data”. National
Tax Journal, 65(1), 117-150.
Dwenger, Nadja, Johanna Storck, and
Katharina Wrohlich. 2012. “Do tuition fees
affect the mobility of university applicants?
Evidence from a natural experiment”. Economics of Education Review, 31(1), 155-167.
Dwenger, Nadja. 2014. “User cost elasticity
of capital revisited”. Economica, 81, 161186.
187
187
Dwenger, Nadja and Viktor Steiner. 2014.
“Financial leverage and corporate taxation.
Evidence from German corporate tax return
data”. International Tax and Public Finance,
21(1), 1-28 (lead article).
Braun, Sebastian, Nadja Dwenger, Dorothea
Kübler, and Alexander Westkamp. 2014.
“Implementing quotas in university admissions: An experimental analysis”. Games and
Economic Behavior, 85, 232-251.
Schön, Wolfgang, Nadja Dwenger, et al.
2014. “Debt and equity in domestic and
international tax law. A comparative policy
analysis”. British Tax Review, 2(2), 146-217.
Becker, Johannes and Nadja Dwenger. 2013.
“Die Besteuerung von Fremd- und Eigenkapital aus ökonomischer Sicht”. In: Schön,
Wolfgang (ed.), Eigenkapital und Fremdkapital. Steuerrecht, Gesellschaftsrecht, Rechtsvergleich, Rechtspolitik. Berlin/Heidelberg:
Springer, 101-124.
Discussion Papers
Dwenger, Nadja, Dorothea Kübler, and
Georg Weizsäcker. 2012. “Preference for
randomization: empirical and experimental
evidence”. Working Paper of the Max
abstract=2192422).
Boyer, Pierre, Nadja Dwenger, and Johannes
Rincke. 2014. “Do taxes crowd out intrinsic
motivation? Field-experimental evidence
from Germany”. Working Paper of the Max
abstract=2540539).
May Elsayyad
Books
Elsayyad, May. 2012. Fighting tax havens
and climate change. Dissertation, LudwigMaximilians-Universität München, Depart-
188
ment of Economics (http://edoc.ub.unimuenchen.de/15031/).
Journal Articles
Elsayyad, May and Kai A. Konrad. 2012.
“Fighting multiple tax havens”. Journal of
International Economics, 86(2), 295-305.
Becker, Johannes, May Elsayyad, and
Clemens Fuest. 2012. “Die Auswirkung der
Globalisierung auf die Struktur der Besteuerung”. Perspektiven der Wirtschaftspolitik,
13(1-2), 4-18.
Elsayyad, May and Shima’a Hanafy. 2014.
“Voting Islamist or voting secular? An
empirical analysis of voting outcomes in
‘Arab Spring’ Egypt”. Public Choice, 160(1-2),
109-130.
Elsayyad, May. 2013. “Steueroasen: Wie
über den Austausch von Informationen
verhandelt wird / Bargaining over tax
information exchange”. 2013 Yearbook
JB_20131?c=7291695).
Discussion Papers
Elsayyad, May. 2012. “Bargaining over tax
information exchange”. Working Paper of
Elsayyad, May and Florian Morath. 2012.
“Technology transfers for climate change”.
(http://ssrn.com/abstract=2166205) and
CESifo Working Paper No. 4521.
Gerritsen, Aart
Books
Gerritsen, Aart. 2014. Essays in optimal
government policy. Doctoral Thesis 577
of the Tinbergen Institute Research Series
(http://repub.eur.nl/pub/76077).
Discussion Papers
Gerritsen, Aart. 2014. “Equity and efficiency
in rationed labor markets”. Mimeo.
Gerritsen, Aart. 2014. “Optimal taxation
when people do not maximize well-being”.
Mimeo.
Gerritsen, Aart and Bas Jacobs. 2014. “Is
a minimum wage an appropriate instrument for redistribution?”. CESifo Working
Paper No. 4588 (http://ssrn.com/abstract=2393889).
Gerritsen, Aart and Bas Jacobs. 2014. “De
welvaartsgevolgen van een lager minimumloon”. A Dutch addendum on the Netherlands for CESifo WP 4588. Mimeo.
Gerritsen, Aart and Bas Jacobs. 2014.
“Minimum wages and taxation in competitive labor markets with endogenous skill
formation”. Mimeo (http://people.few.eur.
nl/bjacobs/minwage1.pdf).
Gerritsen, Aart, Bas Jacobs, Alexandra Rusu,
and Kevin Spiritus. 2014. “Optimal capital
taxation when people face different rates of
return”. Mimeo.
Press Articles
Gerritsen, Aart. 2014. “Werk voor bijstand,
beleidsevaluatie en welvaartstheorie”. ESB
blog, 3 January.
Gerritsen, Aart and Bas Jacobs. 2014. “Dat
minimumloon kan best wat lager”. NRC
Handelsblad, 21 February.
Luisa Herbst
Forthcoming Journal Articles
Herbst, Luisa, Kai A. Konrad, and Florian
Morath. 2012. “Endogenous group formation in experimental contests”. Working
ssrn.com/abstract=2166206). 2015. European Economic Review, 74, 163–189.
Discussion Papers
Herbst, Luisa, Florian Morath, and Kai
A. Konrad. 2014. “Balance of power and
the propensity of conflict”. Max Planck
Working Paper 2014-13 (http://ssrn.com/
abstract=2471532).
Michael Hilmer
Discussion Papers
Hilmer, Michael. 2013. “Fiscal treatment
of managerial compensation – a welfare
analysis”. Working Paper of the Max
abstract=2277461).
Hilmer, Michael. 2014 “Bailouts, bonuses
and bankers’ short-termism”. Working Paper
com/abstract= 2506518).
Gerritsen, Aart. 2014. “Gratis geld bestaat
niet”. ESB blog, 5 March.
Hilmer, Michael. 2014 “Too many to fail
– How bonus taxation prevents gambling
for bailouts”. Working Paper of the Max
abstract=2506526).
Gerritsen, Aart and Bas Jacobs. 2014. “Armen geholpen met lastenverlichting én lager
minimumloon”. MeJudice, 18 March.
Erik Hornung
Interviews
Journal Articles
Gerritsen, Aart. 2014. Radio interview at
BNR Nieuwsradio, 19 February.
Hornung, Erik, 2014. “Immigration and the
diffusion of technology: the Huguenot dias-
189
189
pora in Prussia”. American Economic Review,
104(1), 84-122.
Becker, Sascha, Francesco Cinnirella, Erik
Hornung, and Ludger Wößmann. 2014.
“iPEHD – The ifo Prussian Economic History
Database”. Historical Methods, 47(2), 57-66.
Hornung, Erik. 2014. “Railroads and
growth in Prussia” (http://ssrn.com/abstract=2399352). Journal of the European
Economic Association, forthcoming.
Discussion Papers
Cinnirella, Francesco and Erik Hornung.
2013. “Landownership concentration and
the expansion of education”. CEPR Discussion Paper No. DP9730 (http://ssrn.com/
abstract=2353887) and CAGE Online Working Paper Series No. 175.
Changxia Ke
Journal Articles
Ke, Changxia, Kai A. Konrad, and Florian
Morath. 2013. “Brothers in arms – an
experiment on the alliance puzzle”. Games
and Economic Behavior, 77(1), 61-76.
Morath. 2012. “Alliances in the shadow
of conflict”. Working Paper of the Max
Finance No. 2012-03 (http://ssrn.com/abstract=2029085) and CESifo Working Paper
Series No. 4056. 2015. Economic Inquiry,
53(2), 854-871.
Kai A. Konrad
Books
Konrad, Kai A. and Holger Zschäpitz. 2012.
Schulden ohne Sühne? Was Europas Krise
190
uns Bürger kostet. Third, completely revised
and expanded edition. München: dtv.
First edition: 2010. Schulden ohne Sühne?
Warum der Absturz der Staatsfinanzen uns
alle trifft. München: Verlag C.H. Beck.
Konrad, Kai A., Ronnie Schöb, Marcel Thum,
and Alfons Weichenrieder (eds.). 2013. Die
Zukunft der Wohlfahrtsgesellschaft. Festschrift für Hans-Werner Sinn. Frankfurt a.
M.: Campus.
Journal Articles
Konrad, Kai A. 2012. “Dynamic contests
and the discouragement effect”. Revue
d’Economie Politique, 122(2), 233-256.
Konrad, Kai A. 2012. “Information alliances
in contests with budget limits”. Public
Choice, 151(3-4), 679-693.
Konrad, Kai A. and Dan Kovenock. 2012.
“The lifeboat problem”. European Economic
Review, 56(3), 552-559.
Konrad, Kai A. and Dan Kovenock. 2012.
“Introduction – symposium on advances in
the theory of contests and its applications”,
Economic Theory, 51(2), 241-245.
Konrad, Kai A. and Florian Morath. 2012.
“Evolutionarily stable in-group favoritism
and out-group spite in intergroup conflict”.
Journal of Theoretical Biology, 306, 61-67.
Konrad, Kai A. and Salmai Qari. 2012. “The
last refuge of a scoundrel? Patriotism and
tax compliance”. Economica, 79(315), 516533.
Konrad, Kai A. and Stergios Skaperdas.
2012. “The market for protection and the
origin of the state”. Economic Theory, 50(2),
417-443.
Elsayyad, May and Kai A. Konrad. 2012.
“Fighting multiple tax havens”. Journal of
International Economics, 86(2), 295-305.
Qari, Salmai, Kai A. Konrad, and Benny
Geys. 2012. “Patriotism, taxation and international mobility”. Public Choice, 151(3-4),
695-717.
Konrad, Kai A. 2014. “Search duplication
in research and design spaces – exploring
the role of local competition”. International
Journal of Industrial Organization, 37, 222228.
Konrad, Kai A. and Thomas R. Cusack. 2014.
“Hanging together or being hung separately:
the strategic power of coalitions where
bargaining occurs with incomplete information”. Journal of Conflict Resolution 58(5),
920-940.
Konrad, Kai A., Tim Lohse, and Salmai Qari.
2014. “Deception choice and self-selection
– the importance of being earnest”. Journal
of Economic Behavior & Organization, 107,
25-39.
Konrad, Kai A., Florian Morath, and Wieland
Müller. 2014. “Taxation and market power”.
Canadian Journal of Economics, 47(1), 173202.
Konrad, Kai A. and Marcel P. Thum. 2014.
“The role of economic policy in climate
change adaption”. CESifo Economic Studies, 60(1), 32-61. Blog post on the article:
What is the role of governments in climate
change adaptation? (with Marcel P. Thum),
Oxford University Press‘s blog (http://blog.
oup.com/2014/07/government-adaptationclimate-change/), 23.07.2014.
Konrad, Kai A. and Marcel P. Thum. 2014.
“Climate policy negotiations with incomplete information”. Economica, 81(322),
244-256.
Herbst, Kai A. Konrad, and Florian Morath.
2012. “Endogenous group formation in experimental contests”. Working Paper of the
Finance No. 2012-10 (http://ssrn.com/abstract=2166206). 2015. European Economic
Review, 74, 163–189.
Finance 2012-03 (http://ssrn.com/abstract=2029085) and and CESifo Working
Paper Series No. 4056. 2015. Economic
Inquiry, 53(2), 854-871.
“Evolutionary determinants of war”. Working Paper of the Max Planck Institute for Tax
ssrn.com/abstract=2187218). Defence and
Peace Economics, forthcoming.
Konrad, Kai A. 2013. “Affection, speed dating and heart breaking”. WZB Discussion
Paper SP II 2013-309 (bibliothek.wzb.eu/
pdf/2013/ii13-309.pdf). Journal of Population Economics, forthcoming.
Werding, Martin and Kai A. Konrad. 2012.
“Reforming the European welfare state”. In:
Buettner, Thiess, and Wolfgang Ochel (eds.),
The Continuing Evolution of Europe. CESifo
Summer Series. Cambridge, MA/London:
MIT Press, 71-118.
Konrad, Kai A. 2013. “Die Rolle von nationaler Identität für die öffentliche Wirtschaft”. In: Konrad, Kai A., Ronnie Schöb,
Marcel Thum, and Alfons Weichenrieder
(eds.), Die Zukunft der Wohlfahrtsgesellschaft. Festschrift für Hans-Werner Sinn.
Frankfurt a. M.: Campus, 217-231.
Konrad, Kai A. 2013. “Haushaltsdisziplin
in Deutschland unter der Perspektive
des Bremen-Syndroms”. In: Heintzen,
Markus (ed.), Auf dem Weg zu nachhaltig
ausgeglichenen öffentlichen Haushalten.
Baden-Baden: Nomos, 45-57. Published also
in: 2014. Gesmann-Nuiss, Dagmar, Ronald
Hartz, and Markus Dittrich (eds.), Perspektiven der Wirtschaftswissenschaften. Wiesbaden: Springer Gabler Verlag, 109-122.
Konrad, Kai A. 2013. “Ursachen der
Schuldenkrise und Konzepte zu ihrer
Bewältigung”. In: Yavaşlar, Funda Başaran
(ed.), Finanzkrise in der Europäischen Union
191
191
und ihre Einflüsse auf die Türkei (Avrupa
Birliğinde Mali Kriz ve Türkiye’ye Etkileri).
Ankara: Seçkin, 65-74.
Keen, Michael and Kai A. Konrad. 2013.
“The theory of international tax competition
and coordination”. In: Auerbach, Alan J., Raj
Chetty, Martin Feldstein, and Emmanuel
Saez (eds.), Handbook of Public Economics.
Amsterdam/Oxford: Elsevier, 257-328.
Konrad, Kai A. 2014. “Wer hat Angst vorm
bösen Wort?”. Der Hauptstadtbrief – Informations- und Hintergrund-Dienst aus Berlin,
16(120), 30-32.
Konrad, Kai A. 2014. “Strategic aspects of
fighting in alliances”. In: Wärneryd, Karl
(ed.), The Economics of Conflict. Cambridge/
London: The MIT Press, 1-22.
Konrad, Kai A. 2014. “Der Traum eines
Finanzministers ist die Entschuldung im
Schlaf”. Der Hauptstadtbrief – Informationsund Hintergrund-Dienst aus Berlin, 16(122),
28-31.
Policy Papers and Reports
Konrad, Kai A. 2014. “Balancing austerity
and strategies for growth”. CFA Institute
Conference Proceedings Quarterly. Second
Quarter, 1-8.
Konrad, Kai A. 2012. “Den Euro retten,
Europa preisgeben?”. Der Hauptstadtbrief
– Informations- und Hintergrund-Dienst aus
Berlin, 14(108), 9-12.
Konrad, Kai A. 2012. “Kommentar zum
Vortrag von Joachim Weimann: Wie sinnvoll ist der klimapolitische Alleingang
Deutschlands?”. ifo Schnelldienst, 65(12),
40-41. Published also as: 2012. “Zum
deutschen Sonderweg in der Klimapolitik:
Ergänzende Betrachtungen”. In: Rundgespräche der Kommission für Ökologie, Die
Zukunft der Energieversorgung, 41, 165-168.
Konrad, Kai A. 2013. “Der Staat entschuldet
sich, der Sparer zahlt die Zeche”. Der Hauptstadtbrief, (15)113, 7-11.
Konrad, Kai A. 2013. “Haftungsrisiken und
Fehlanreize aus ESM und OMT-Programm”.
Wirtschaftsdienst, 93(7), 431-439. Revised
version of the expert report commissioned
by the German Constitutional Court. June
2013. “Stellungnahme gegenüber dem
Bundesverfassungsgericht zu den Verfahren
mit den Az. 2 BvR 1390/12, 2 BvR 1421/12,
2 BvR 1438/12, 2 BvR 1439/12, 2 BvR
1440/12, 2BvR 1824/12, 2 Bve 6/12”.
Konrad, Kai A. 2013. “Steuerflucht und
Steueroasen – Lässt sich der Kampf gegen
die Steueroasen gewinnen?”. Wirtschaftsdienst, 93(6), 359-362.
Konrad, Kai A. and Holger Zschäpitz. 2013.
“The future of the Eurozone”. In: Flick,
192
Corinne Michaela (ed.), Can’t pay, won’t
pay? Sovereign debt and the challenge of
growth in Europe, Convoco Edition, 93-106.
First published in German, Frankfurt a.
Main: Convoco Edition, 2010.
Konrad, Kai A. 2014. “‘Lackmustest’ zur Stabilitätsunion”. Wirtschaftsdienst, 94(3), 154.
Konrad, Kai A., Thiess Büttner, and Jörg
Rocholl. 2014. “Privilegien des Staates auf
dem Prüfstand”. Wirtschaftsdienst, 94(8),
560-563.
Konrad, Kai A., and Ronnie Schöb. 2014.
“Fracking in Deutschland – eine Option für
die Zukunft!”. Wirtschaftsdienst, 94(9), 645654. Further publication: Ökonomenstimme,
10 October.
Konrad, Kai A., 2014. “Gefährliche Wetten”.
In: Flick, Corinne Michaela (ed.), Rechnen
mit dem Scheitern: Strategien in ungewissen
Zeiten. Göttingen, Convoco Edition, 115-122.
English version: Konrad, Kai A., 2014. “Dangerous wagers”. In: Flick, Corinne Michaela
(ed.), Dealing with Downturns: Strategies in
Uncertain Times, 123-133.
Expertise
Council of the Scientific Advisors to the
Ministry of Finance. March 2012. Expertise
“Die Begünstigung des Unternehmensvermögens in der Erbschaftsteuer” (http://
www.bundesfinanzministerium.de/Content/
DE/Standardartikel/Ministerium/Geschaeftsbereich/Wissenschaftlicher_Beirat/
Gutachten_und_Stellungnahmen/Aus-
gewaehlte_Texte/02-03-2012-ErbSt-anl.
pdf?__blob=publicationFile&v=4).
“Fiskalpolitische Institutionen in der Eurozone” (http://www.bundesfinanzministerium.de/Content/DE/Standardartikel/Ministerium/Geschaeftsbereich/Wissenschaftlicher_Beirat/Gutachten_und_Stellungnahmen/
Ausgewaehlte_Texte/02-03-2012-EurozoneAnlage.pdf?__blob=publicationFile&v=5).
Ministry of Finance. November 2012.
Expertise “Ein Haushalt für Europa – Stellungnahme zum mehrjährigen Finanzrahmen der EU 2014 - 2020” (http://www.
bundesfinanzministerium.de/Content/
DE/Standardartikel/Themen/Europa/
EU_auf_einen_Blick/EU_Haushalt/201211-23-Stellungnahme-Finanzrahmen-EU.
Project “Anpassungsstrategien in der
Klimapolitik”. September 2012. Expertise
“Anpassungsstrategien in der Klimapolitik”.
acatech Position. Heidelberg u.a.: SpringerVerlag (http://www.acatech.de/fileadmin/
user_upload/Baumstruktur_nach_Website/
Acatech/root/de/Publikationen/Stellungnahmen/acatech_POSITION_Klimawandel_WEB.pdf).
Ministry of Finance. January 2013. Expertise
“Finanzpolitische Herausforderungen des
demografischen Wandels im föderativen
System” (http://www.bundesfinanzministerium.de/Content/DE/Downloads/
Broschueren_Bestellservice/201306-28-finanzpolitische-herausforderungen-demografischer-wandel-anlage.
Ministry of Finance. February 2013.
Expertise “Besteuerung von Vermögen.
Eine finanzwissenschaftliche Analyse”
(http://www.bundesfinanzministerium.
de/Content/DE/Downloads/Broschueren_
Bestellservice/2013-07-01-vermoegensteuer-anlage.pdf?__blob=publicationFile&v=5).
Ministry of Finance. January 2014. Expertise
“Stellungnahme zur aktuellen Entwicklung
der Europäischen Bankenunion” (http://
www.bundesfinanzministerium.de/
Content/DE/Downloads/Broschueren_
Bestellservice/2014-04-10-stellungnahmeeuropaeische-bankenunion-anlage.
Ministry of Finance. February 2014. Expertise „Der Staat als privilegierter Schuldner
– Ansatzpunkte für eine Neuordnung der
öffentlichen Verschuldung in der Europäischen Währungsunion” (http://www.bundesfinanzministerium.de/Content/DE/Downloads/Broschueren_Bestellservice/201404-10-gutachten-staat-als-schuldner-anlage.
“Öffentlich-rechtliche Medien – Aufgabe
und Finanzierung” (http://www.bundesfinanzministerium.de/Content/DE/Downloads/Broschueren_Bestellservice/201412-15-gutachten-medien.pdf?__
blob=publicationFile&v=9).
Ministry of Finance. November 2014. Letter
“Expertise Keine Rückkehr zur Schuldenpolitik der Vergangenheit! Zur Debatte über
Investitionen und Staatsverschuldung in
Deutschland” (http://www.bundesfinanzministerium.de/Content/DE/Downloads/
Abt_2/2014-11-25-Gutachten-Beirat.
Press Articles
Konrad, Kai A. 2012. “Karlsruher Richter
können den Spielraum erweitern”. Die Welt,
10 July.
Konrad, Kai A. 2012. “Die Illusionen der Klimapolitik”. Frankfurter Allgemeine Zeitung,
17 December.
Konrad, Kai A. and Ronnie Schöb. 2014.
“Fracking? Später vielleicht”. Die Zeit, 23
December.
193
193
Interviews
Konrad, Kai A. 2012. “Europa und der Euro
sind zwei völlig unterschiedliche Dinge”.
Wirtschaftswissenschaftliches Studium,
1(41).
Konrad, Kai A. 2012. “Deiche statt Windräder”. Der Spiegel, 3 December.
Konrad, Kai A. 2013. “Auch 60 Prozent
Schulden sind zu viel”. Welt am Sonntag, 21
April.
Konrad, Kai A. 2013. “Europa schwer beschädigt”. Focus Money, 30 April.
Konrad, Kai A. 2013. “Wenn, dann muss
Deutschland raus”. Die Welt, 17 August.
Konrad, Kai A. 2013. “Als Zahlmeister ist
Deutschland zu klein und nicht wohlhabend
genug”. feine adressen, 1 December.
Konrad, Kai A. 2013. “Nachgefragt bei Kai
Konrad: Wenn Speed-Dater Herzen brechen”. WZB Mitteilungen, December.
Konrad, Kai A. 2014. “Deutschland zieht
den Euro hoch”. Finanz und Wirtschaft, 26
February.
Konrad, Kai A. 2014. “Le projet européen
doit être sauvé, pas forcément l’euro“ /
Das europäische Projekt muss gerettet
werden, nicht notwendigerweise der Euro”. L’Expansion, February.
Konrad, Kai A. 2014. “Wie verändert sich
die deutsche Politik, wenn die Konjunktur
wieder stottert?“. NZZ Podium in Berlin.
Neue Zürcher Zeitung online, October.
Discussion Papers
Konrad, Kai A. and Michael Keen. 2012.
“The theory of international tax competition
and coordination”. Working Paper of the
abstract=2111895).
Konrad, Kai A. and Marcel Thum. 2012.
“The role of economic policy in climate
change adaptation”. Working Paper of the
194
abstract=2158578), CESifo Working Paper
Series No. 3959 and EIB Working Papers
2012/02.
2012. “Customs compliance and the power
of imagination”. CESifo Working Paper
Series No. 3702 (http://ssrn.com/abstract
id=1990188).
Konrad, Kai A., Tim Lohse, and Salmai
Qari. 2013. “Dubious versus trustworthy
faces – what difference does it make for
tax compliance?”. CESifo Working Paper
Series No. 4373 (http://ssrn.com/abstract_
id=2319853).
Konrad, Kai A., and Adalbert Winkler. 2014.
“Pro & Contra: OMT-Urteil des Bundesverfassungsberichts”. Munich Reprints in
Economics (http://econpapers.repec.org/
paper/lmumuenar/22063.htm).
Buchholz, Wolfgang and Kai A. Konrad.
2014. “Taxes on risky returns – An update”.
Finance Working Paper No. 2014-10 (http://
Herbst, Luisa, Florian Morath, and Kai
A. Konrad. 2014. “Balance of power and
abstract=2471532).
Boyer, Pierre and Kai A. Konrad. 2014. “Targeted campaign competition, loyal voters,
and supermajorities”. Working Paper of the
abstract=2474987).
Bronsert, Anne-Kathrin, Amihai Glazer,
and Kai A. Konrad. 2014. “Old money,
the nouveaux riches and Brunhilde’s marriage strategy”. Working Paper of the Max
Finance No. 2014-15 (http://ssrn.com/abstract=2476388) and IZA DP No. 8307.
“Bargaining with incomplete information:
evolutionary stability in finite populations”.
Konrad, Kai A. and Marcel Thum. 2014.
“Does a clean development mechanism
facilitate international environmental agreements?”. Working Paper of the Max Planck
No. 2014-20 (http://ssrn.com/abstract=
2518349).
Harald Lang
Lang, Harald. 2013. “Konferenzbericht:
Wege zu einer neuen Fiskalpolitik in Europa”. WZB Mitteilungen, March.
Lang, Harald. 2013. “Fiscal policy: Europe at
a crossroads”. Newsletter of the Max Planck
Institute for Tax Law and Public Finance,
01/2013 (http://www.tax.mpg.de/files/
pdf2/2103-07-22_Interaktiv1.pdf).
Tim Lohse
and Exchange Commission?”. Working Paper
Discussion Papers
Meyer-Brauns, Philipp. 2013. “Multitasking
in corporate tax evasion”. Working Paper
Meyer-Brauns, Philipp. 2014. “Financial
contracting with tax evaders”. Working Paper of the Max Planck Institute for Tax Law
and Public Finance No. 2014-01 (http://ssrn.
Meyer-Brauns, Philipp. 2014. “Optimal
auditing with heterogeneous audit perceptions”. Working Paper of the Max
abstract=2430241).
Journal Articles
Rhea Molato
Lohse, Tim, and Salmai Qari. 2014. “Gender
differences in deception behaviour – the
role of the counterpart”. Applied Economics
Letters, 21(10), 702-705.
Dissertation
of Economic Behavior & Organization, 107, 25-39.
Molato, Rhea. 2014. Differences in the public sector: essays on secession threats and
wage differentials. Inaugural Dissertation,
Department of Economics.
Florian Morath
Discussion Papers
Journal Articles
2013. “Dubious versus trustworthy faces
– what difference does it make for tax compliance?”. CESifo Working Paper Series No.
4373 (http://ssrn.com/abstract=2319853).
“Evolutionarily stable in-group favoritism
and out-group spite in intergroup conflict”.
Journal of Theoretical Biology, 306, 61-67.
Lohse, Tim, and Christian Thomann. 2014.
“Are bad times good news for the Securities
Morath, Florian. 2013. “Volunteering and
the strategic value of ignorance”. Social
Choice and Welfare, 41(1), 99-131.
195
195
Morath, Florian and Johannes Münster.
2013. “Information acquisition in conflicts”.
Economic Theory, 54(1), 99-129.
Konrad, Kai A., Florian Morath, and Wieland
Müller. 2014. “Taxation and market power”.
Canadian Journal of Economics, 47(1), 173202.
Morath, Florian. 2012. “Marktmacht und
die Wohlfahrtswirkung von Besteuerung /
Market power and the welfare effects of
taxation”. 2012 Yearbook of the Max Planck
Society (Research Report, http://www.
mpg.de/4659308/Wohlfahrtswirkung_
Besteuerung?c=5732343).
Finance 2012-03 (http://ssrn.com/abstract=2029085) and CESifo Working Paper
Series No. 4056. Economic Inquiry, 2015,
53(2), 854-871.
“Evolutionary determinants of war”. Working Paper of the Max Planck Institute for Tax
ssrn.com/abstract=2187218). Defence and
Peace Economics, forthcoming.
Morath. 2012. “Endogenous group formation in experimental contests”. Working
ssrn.com/abstract=2166206). 2015. European Economic Review, 74, 163–189.
196
Kovenock, Dan, Florian Morath, and Johannes Münster. 2010. “Information sharing
in contests”. SFB/TR 15 Discussion Paper No.
334 and Journal of Economics & Management Strategy, forthcoming.
Discussion Papers
Elsayyad, May and Florian Morath. 2012.
“Technology transfers for climate change”.
(http://ssrn.com/abstract=2166205) and
CESifo Working Paper No. 4521.
Dang, Tri Vi and Florian Morath. 2013. “The
taxation of bilateral trade with endogenous
information”. Working Paper of the Max
Finance No. 2013-07 (http:// ssrn.com/
abstract=2361365).
Morath. 2014. “Balance of power and
abstract=2471532).
“Bargaining with incomplete information:
Evolutionary stability in finite populations”.
Finance Working Paper 2014-16 (http://ssrn.
Morath, Florian and Johannes Münster.
2014. “Online shopping and platform design
with ex ante registration requirements”.
Finance Working Paper 2014-21 (http://ssrn.
Salmai Qari
Books
Qari, Salmai. 2012. Tax avoidance, household formation and inequality. Dissertation,
Berlin: Freie Universität Berlin (http://www.
diss.fu-berlin.de/diss/receive/FUDISS_thesis_000000038191).
Journal Articles
Qari, Salmai, Kai A. Konrad, and Benny
Geys. 2012. “Patriotism, taxation and international mobility”. Public Choice, 151(3-4),
695-717.
Konrad, Kai A. and Salmai Qari. 2012. “The
last refuge of a scoundrel? Patriotism and
tax compliance”. Economica, 79(315), 516533.
Hendel, Ulrich and Salmai Qari. 2014.
“Immigration and attitudes towards day
care”, Social Indicators Research, 119(2), S.
997–1029.
of Economic Behavior & Organization, 107, 25-39.
Lohse, Tim and Salmai Qari. 2014. “Gender
differences in deception behaviour – the
role of the counterpart”. Applied Economics
Letters 21 (10), 702-705.
Qari, Salmai. 2014. “Marriage, Adaptation
and Happiness: Are there long-lasting Gains
to Marriage?”. Journal of Behavioral and
Experimental Economics, 50, 29-39.
Qari, Salmai. 2014. “Geschlechtsspezifische
Effekte beim Lügen bei der Steuererklärung
/ Gender differences in tax compliance
behavior”. 2014 Yearbook of the Max Planck
Society (Research Report, http://www.mpg.
de/7746757/JB_20141?c=8236817).
Lohse, Tim and Salmai Qari. 2014. “Gendereffekte bei Risikoneigung und Lügen - Evidenz aus einem Compliance-Experiment”.
Wirtschaftswissenschaftliches Studium, 43,
91-97.
of imagination”. CESifo Working Paper
Series No. 3702 (http://ssrn.com/abstract
id=1990188).
Konrad, Kai A., Tim Lohse, and Salmai
Qari. 2013. “Dubious versus trustworthy
faces – what difference does it make for
tax compliance?”. CESifo Working Paper
Series No. 4373 (http://paper.ssrn.com/
abstract_id=2319853).
Fangfang Tan
Books
Tan, Fangfang. 2012. Behavioural heterogeneity in economic institutions: an
experimental approach. Open Access
publications from Tilburg University, ISBN:
978 90 5668 3078 (http://arno.uvt.nl/show.
cgi?fid=121485).
Journal Articles
Tan, Fangfang and Erte Xiao. 2012. “Peer
punishment with third-party approval in a
social dilemma game”. Economics Letters,
117(3), 589-591.
Tan, Fangfang and Erte Xiao. 2012. “Peer
punishment with third-party approval in a
social dilemma game”. Economics Letters,
2012, 117(3), 589-591.
Müller, Wieland and Fangfang Tan. 2013.
“Who acts more like a game theorist? Group
and individual play in a sequential market
game and the effect of the time horizon”
Games and Economic Behavior, 82, 658-674.
Xiao, Erte and Fangfang Tan. 2014. “Justification and legitimate punishment”. Journal
of Institutional and Theoretical Economics,
170(1), 168-188.
Tan, Fangfang and Andrew Yim. 2014. “Can
strategic uncertainty help deter tax evasion?
– An experiment on auditing rules”. Journal
of Economic Psychology, 40, 161-174.
Discussion Papers
2012. “Customs compliance and the power
197
197
Discussion Papers
Fu, Qiang, Changxia Ke, and Fangfang Tan.
2013. “‘Success breeds success’ or ‘Pride
goes before a fall’? Individuals and teams in
the best-of-three contests”. Working Paper
com/abstract_id=2340079).
Tan, Fangfang, and Erte Xiao. 2014.
“Third-party punishment: retribution or
deterrence”. Working Paper of the Max
abstract=2425522).
Kocher, Martin, Fangfang Tan, and Jing Yu.
2014. “Providing global public goods: Electoral delegation and cooperation”. Working
II Lectures at Conferences or
Seminars
Sabine Aresin
“Cross Border Abatement and its Welfare
Effects”, V. Tax Day, MPI for Tax Law and
Public Finance, Munich, January 2012.
Effects”, Poster Presentation, Scientific Advisory Board Meeting, MPI for Tax Law and
Public Finance, Munich, July 2012.
Effects”, VII. Tax Day, MPI for Tax Law and
Public Finance, Munich, September 2012.
Effects”, Öffentliche Finanzen und Politische
Ökonomie I, MPI for Tax Law and Public
Finance, Joint Seminar with Bruno Frey,
Schliersee, May 2013.
Effects”, Public Economic Seminar, LudwigMaximilians-Universität München, Munich,
May 2013.
Effects”, Spring Meeting of Young Economists, Aarhus University, Aarhus, Denmark,
May/June 2013.
Effects”, PET International Meeting, Association for Public Economic Theory, Lisbon,
Portugal, July 2013.
Effects”, 69th Annual Congress of the International Institute of Public Finance, Taormina,
Italy, August 2013.
“Competition and the Clean Development
Mechanism”, Brown Bag Seminar, Simon
Fraser University, Burnaby, Canada, November 2013.
„Import Restrictions on Emission Credits“,
Energie, Klima und erschöpfbare Ressourcen, Ifo-Seminar, Loas, Austria, June 2014.
198
“Old Money, the Nouveaux Riches and
Brunhilde’s Marriage Strategy”, Workshop
Öffentliche Finanzen und Politische Ökonomie II, MPI for Tax Law and Public Finance,
Joint Seminar with Bruno Frey and Marcel
Thum, Munich, June 2014.
Brunhilde’s Marriage Strategy”, Public
Economic Seminar, Ludwig-MaximiliansUniversität München, Munich, June 2014.
Brunhilde’s Marriage Strategy”, 28th Annual
Conference of the European Society for
Population Economics, Braga, Portugal,
June 2014.
Brunhilde’s Marriage Strategy”, 70th Annual
Congress of the International Institute of
Public Finance, Redesigning the Welfare
State for Aging Societies, University of Lugano, Lugano, Switzerland, August 2014.
Brunhilde’s Marriage Strategy”, European
Economic Association Annual Congress,
European Economic Association, Toulouse,
France, August 2014.
Brunhilde’s Marriage Strategy”, Annual
Congress of the Verein für Socialpolitik,
Helmut-Schmidt Universität, Hamburg,
September 2014.
Thomas Daske
“When Altruists Become Selfish – Can we
Deduce Motive from Action?”, V. Tax Day,
MPI for Tax Law and Public Finance, Munich, January 2012.
“Wishing for Enemies? – The Effect of OutGroup Considerations on Collective Action”,
Poster Presentation, VI. Tax Day, MPI for
Tax Law and Public Finance, Munich, May
2012.
“Assigning Teams in a Social Network”,
VIII. Tax Day, MPI for Tax Law and Public
Finance, Munich, March 2013.
Workshop“, ESI Mini Workshop on Experimental Economics III, MPI for Tax Law and
Public Finance and MPI of Economics, Jena,
April 2013.
Micro-Economic Workshop, LudwigMaximilians-Universität München, Munich,
April 2013.
Workshop Öffentliche Finanzen und
Politische Ökonomie I, MPI for Tax Law and
Public Finance, Joint Seminar with Bruno
Frey, Schliersee, May 2013.
“Social Preferences and Work Incentives –
The Role of Uncertainty about a (Co-)Worker’s Type”, Mikroökonomisches Kolloquium,
Freie Universität Berlin, May 2014.
“Social Preferences and Work Incentives
– The Role of Uncertainty about a (Co-)
Worker’s Type”, Micro-Economic Workshop,
Munich, May 2014.
Nadja Dwenger
“Sharing the Burden: Empirical Evidence
on Corporate Tax Incidence”, American
Economic Association, Annual Meeting,
Chicago, USA, January 2012.
“Sharing the Burden: Empirical Evidence on
Corporate Tax Incidence”, Empirical Economics Seminar, Ludwig-Maximilians-Universität München, Munich, January 2012.
Comment on: “Tax Compliance Costs”,
1st FAU Workshop on Tax Compliance,
Friedrich-Alexander-Universität ErlangenNürnberg, Nuremberg, March 2012.
Corporate Tax Incidence”, Royal Economic
Society, Annual Conference, Cambridge, UK,
March 2012.
Corporate Tax Incidence”, Seminar, Technische Universität Dortmund, Dortmund,
May 2012.
199
199
“Sharing the Burden: Empirical Evidence
on Corporate Tax Incidence”, Forschungs
seminar für Wirtschaftspolitik und quantitative Wirtschaftsforschung, FriedrichAlexander-Universität Erlangen-Nürnberg,
Nuremberg, June 2012.
Corporate Tax Incidence”, Poster Presentation, Scientific Advisory Board Meeting, MPI
for Tax Law and Public Finance, Munich,
July 2012.
“Economic vs. Social Incentives in Tax Compliance: Evidence from a Field Experiment in
Germany”, Public Economics Seminar, University of California, Berkeley, USA, October
2012.
Corporate Tax Incidence”, National Tax Conference, Annual Meeting, Providence, USA,
November 2012.
“Randomization: Empirical and Experimental Evidence”, ESI Mini Workshop on Experimental Economics III, MPI for Tax Law and
April 2013.
Comment on: Rita de la Feria and Michael
Devereux, “Implementing a DestinationBased Corporation Tax”, ETPF/CEPS Conference on Financial Sector Taxation, Brussels,
Belgium, May 2013.
Comment on: Andreas Haufler and Christian
Lülfesmann, “Reforming an Asymmetric
Union: On the Virtues of Dual Tier Capital
Taxation”, Annual Symposium, Oxford University Centre for Business Taxation, Oxford,
UK, June 2013.
“Sharing the Burden? Empirical Evidence on
Corporate Tax Incidence”, 69th Annual Congress of the International Institute of Public
Finance, Taormina, Italy, August 2013.
“Sharing the Burden? Empirical Evidence
on Corporate Tax Incidence”, Competition
Policy and Regulation in a Global Economic
Order, Annual Congress of the Verein für
Socialpolitik, Düsseldorf, September 2013.
Comment on: Glen Loutzenhiser, “Small
Business Taxation in the UK”, MunichSydney-Conference on the Law and Economics of Taxation, MPI for Tax Law and Public
September 2013.
“Tax Collection and Tax Compliance.
Empirical Evidence in Field Experiments”,
Best Practices in Tax Collection, European
Commission, Brussels, Belgium, September
2013.
“Economic vs Social Incentives in Tax Compliance: Evidence from a Field Experiment
in Germany”, Steuerpolitik im Umfeld neuer
Fiskalinstitutionen und Abstimmungsverfahren, Internal Workshop, PAKT, Speyer,
October 2013.
in Germany”, Tax Compliance in Field and
Laboratory Experiments, MPI for Tax Law
and Public Finance, Munich, November
2013.
in Germany”, SITE Seminar, Stockholm,
Sweden, November 2013.
“Sharing the Burden? Empirical Evidence
on Corporate Tax Incidence“, Meeting of
the Board of Trustees, MPI for Tax Law and
“Extrinsic and Intrinsic Motivations for Tax
Compliance: Evidence from a Field Experiment in Germany”, IO and Trade Seminar,
“Real Effects of Bank Distress. Evidence from
Individual Firm-Bank Relationships”, ETH
Zurich, Zurich, Switzerland, July 2013.
Compliance: Evidence from a Field Experiment in Germany”, Faculty Seminar, Vallendar, November 2013.
Compliance: Evidence from a Field Experi-
200
ment in Germany”, Public Economics Seminar, Mannheim, December 2013.
“Extrinsic vs Intrinsic Motivations for Tax
Compliance: Evidence from a Field Experiment in Germany”, Faculty Seminar at the
Oxford University Centre for Business Taxation, Oxford, UK, December 2013.
Compliance. Evidence from a Field Experiment in Germany”, American Economic Association, Philadelphia, USA, January 2014.
Compliance. Evidence from a Field Experiment in Germany”, Ludwig-Maximilians-Universität München, Munich, January 2014.
Compliance. Evidence from a Field Experiment in Germany”, Social Science Research
Center Berlin (WZB), Berlin, February 2014.
Compliance. Evidence from a Field Experiment in Germany”, Government Institute for
Economic Research Helsinki (VATT), February 2014.
Compliance. Evidence from a Field Experiment in Germany”, Ludwig-MaximiliansUniversität München, Munich, February
2014.
“Do Taxes Crowd Out Intrinsic Motivation?
Field-Experimental Evidence from Germany“, Taxation, Social Norms and Compliance,
Nuremberg, March 2014.
Compliance. Evidence from a Field Experiment in Germany”, 18th Conference of the
SFB/TR 15, Governance and the Efficiency of
Economic Systems, Mannheim, April 2014.
Compliance. Evidence from a Field Experiment in Germany”, Norwegian School of
Economics, Bergen, Norway, May 2014.
Compliance. Evidence from a Field Experiment in Germany”, University of Copenhagen, Copenhagen, Denmark, May 2014.
Compliance. Evidence from a Field Experiment in Germany”, Workshop “Credible
Identification and Structural Modeling”,
Ohlstadt, June 2014.
Compliance. Evidence from a Field Experiment in Germany”, University of Potsdam,
Potsdam, June 2014.
“Extrinsic and Intrinsic Motivations for
Tax Compliance. Evidence from a Field
Experiment in Germany”, Public Economics
Committee of the Verein für Socialpolitik,
Bremen, June 2014.
Compliance. Evidence from a Field Experiment in Germany”, Öffentliche Finanzen
und Politische Ökonomie II, MPI for Tax
Law and Public Finance, Joint Seminar with
Bruno Frey and Marcel Thum, Munich, June
2014.
Compliance. Evidence from a Field Experiment in Germany”, arqus-Jubiläumstagung,
Bayreuth, July 2014.
Compliance. Evidence from a Field Experiment in Germany”, NBER Summer Institute,
Cambridge, USA, July 2014.
Compliance. Evidence from a Field Experiment in Germany”, University of Trier, Trier,
July 2014.
Compliance. Evidence from a Field Experiment in Germany”, Annual Congress of the
Verein für Socialpolitik, Helmut-Schmidt
Universität, Hamburg, September 2014.
Compliance. Evidence from a Field Experiment in Germany”, University of Bochum,
Bochum, May 2014.
201
201
“Steuerehrlichkeit und Steuerdurchsetzung.
Empirische Evidenz durch Feldexperimente”,
Arbeitskreis Finanzwissenschaft, German
Federal Ministry of Finance, Berlin, October
2014.
“Do Taxes Crowd Out Intrinsic Motivation?
Field-Experimental Evidence from Germany”, ESI Mini Workshop on Experimental
Economics II, University of Innsbruck, Innsbruck, Austria, October 2014.
“Improving Tax Collection by Public Shaming”, University of California, Berkeley, USA,
November 2014.
May Elsayyad
“Technology Transfers for Climate Change”,
IO and Trade Seminar, Ludwig-MaximiliansUniversität München, Munich, February
2012.
“Bargaining Over Tax Information Exchange”,
Munich, March 2012.
IO and Trade Seminar, Ludwig-MaximiliansUniversität München, Munich, April 2012.
VI. Tax Day, MPI for Tax Law and Public
Finance, Munich, May 2012.
Vereinstagung für Socialpolitik 2012, Göttingen, September 2012.
ESI Mini Workshop on Experimental
Economics II, MPI for Tax Law and Public
Finance, Munich, October 2012.
Aart Gerritsen
“Optimal Taxation When People Do Not
Maximize Well-Being”, IX. Tax Day, MPI for
Tax Law and Public Finance, Munich, August
2013.
“Is a Minimum Wage an Appropriate Instrument for Redistribution?”, X. Tax Day, MPI
202
November 2013.
Organisator of the Tinbergen Institute Workshop on Public Economics, Erasmus University Rotterdam, Rotterdam, Netherlands,
February 2014.
“Essays over optimaal overheidsbeleid – het
lekenpraatje”, Erasmus University Rotterdam, Rotterdam, Netherlands, February
2014.
“Equity and Efficiency in Rationed Labor
Markets”, XI. Tax Day, MPI for Tax Law and
Public Finance, Munich, March 2014.
“Optimal Taxation when People Do Not
Maximize Well-Being”, CESifo Area Conference on Public Sector Economics, CESifo
Group, Munich, April 2014.
Maximize Well-Being”, Centre for Economic
Development and Institutions Conference,
London, UK, May 2014.
Maximize Well-Being”, Öffentliche Finanzen
und Politische Ökonomie II, MPI for Tax
Law and Public Finance, Joint Seminar with
Bruno Frey and Marcel Thum, Munich, June
2014.
Maximize Well-Being”, Seminar at the University of Siegen, Siegen, July 2014.
Maximize Well-Being”, Public Economic
Theory Conference, Seattle, USA, July 2014.
Maximize Well-Being”, 70th Annual Congress
of the International Institute of Public
Finance, Redesigning the Welfare State
for Aging Societies, University of Lugano,
Lugano, Switzerland, August 2014.
“Is a Minimum Wage an Appropriate
Instrument for Redistribution?”, European
“Is a Minimum Wage an Appropriate
Instrument for Redistribution?”, ESI Mini
Workshop on Experimental Economics II,
University of Innsbruck, Innsbruck, Austria,
October 2014.
“Optimal Capital Taxation when People Face
Different Rates of Return”, De Nederlandse
Economendag, Amsterdam, Netherlands,
October 2014.
“Optimal Capital Taxation when People Face
Different Rates of Return,” XIII. Tax Day, MPI
November 2014.
Luisa Herbst
“Endogenous Alliance Formation in Experimental Contests”, 7th FFF Stipend-ResearchWorkshop, Social Science Research Center
Berlin (WZB), Berlin, February 2012.
“Endogenous Alliance Formation in Experimental Contests”, Poster Presentation,
Conference on Contests, Mechanisms and
Experiments, University of Exeter, UK, April
2012.
“Endogenous Alliance Formation in Experimental Contests”, VI. Tax Day, MPI for Tax
Law and Public Finance, Munich, May 2012.
“Contests of Three Parties”, 8th FFF
Stipend-Research-Workshop, Social Science
Research Center Berlin (WZB), Berlin, June
2012.
“Endogenous Alliance Formation in Experimental Contests”, Presentation and
Poster Presentation, Scientific Advisory
Board Meeting, MPI for Tax Law and Public
“Balance of Power and the Probability of
Conflict”, 7th Young Researchers Workshop,
Economic Systems, Bonn, April 2013.
“Endogenous Group Formation in Experimental Contests”, Florence Workshop on
Behavioural and Experimental Economics,
Florence, Italy, May 2013.
“Endogenous Group Formation in Experimental Contests”, Öffentliche Finanzen und
“Endogenous Group Formation in Experimental Contests”, Spring Meeting of Young
Economists, Aarhus University, Aarhus,
Denmark, May/June 2013.
“Endogenous Group Formation in Experimental Contests”, Workshop “Competition between Conflict and Cooperation”,
Freiburg, June 2013.
“Endogenous Group Formation in Experimental Contests”, PET International Meeting, Association for Public Economic Theory,
Lisbon, Portugal, July 2013.
“Endogenous Group Formation in Experimental Contests”, 69th Annual Congress of
the International Institute of Public Finance,
Taormina, Italy, August 2013.
“Endogenous Group Formation in Experimental Contests”, 28th European Economic
Association Meeting, Gothenburg, Sweden,
August 2013.
Co-organisator of the Tinbergen Institute
Workshop on Public Economics, Erasmus
University Rotterdam, Rotterdam, Netherlands, February 2014.
“Endogenous Alliance Formation in Experimental Contests”, Ph.D. Course with John
List “Field and Lab Experiments in Economics”, Norwegian School of Economicst,
Bergen, Norway, October 2012.
“Bargaining with Pre-Investments”, 9th Young
Researchers Workshop of the SFB/TR 15,
Governance and the Efficiency of Economic
Systems, Mannheim, April 2014.
“Endogenous Group Formation in Experimental Contests”, 16th Conference of the
Economic Systems, Bonn, April 2013.
“Balance of Power and the Propensity of Conflict”, Öffentliche Finanzen und
Politische Ökonomie II, MPI for Tax Law and
Frey and Marcel Thum, Munich, June 2014.
203
203
“Balance of Power and the Propensity of
Conflict”, PET 2014 15th International Conference on Public Economics, University of
Washington, Seattle, USA, July 2014.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, PET International
Meeting, Association for Public Economic
Theory, Lisbon, Portugal, July 2013.
Conflict”, ESA Economic Science Association
2014 European Meeting, Prague, Czech
Republic, September 2014.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, Competition
Policy and Regulation in a Global Economic
Order, Annual Congress of the Verein für
Conflict”, 19th Conference of the SFB/TR 15,
Governance and the Efficiency of Economic
Systems, Caputh, October 2014.
Conflict”, ESI Mini Workshop on Experimental Economics IV, MPI of Economics, Jena,
October 2014.
Conflict”, ESI Mini Workshop on Experimental Economics II, University of Innsbruck,
Innsbruck, Austria, October 2014.
“Too Many to Fail – How Bonus Taxation
Prevents Gambling for Bailouts”, Public
Finance and Economic Policy Seminar,
Munich, December 2013.
“Too Many to Fail – How Bonus Taxation
Prevents Gambling for Bailouts”, Evidencebased Economic Policy, Annual Congress of
the Verein für Socialpolitik, Helmut-Schmidt
Universität, Hamburg, September 2014.
Erik Hornung
Michael Hilmer
“Incentive Contracting under Limited Liability and Limited Deductibility of Bonuses”, VI.
Tax Day, MPI for Tax Law and Public Finance,
Munich, May 2012.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, Presentation,
Scientific Advisory Board Meeting, MPI for
2012.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, VIII. Tax Day, MPI
March 2013.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, Öffentliche
Finanzen und Politische Ökonomie I, MPI for
Tax Law and Public Finance, Joint Seminar
with Bruno Frey, Schliersee, May 2013.
“Fiscal Treatment of Managerial Compensation – A Welfare Analysis”, Public Finance
and Economic Policy Seminar, LudwigMaximilians-Universität München, Munich,
July 2013.
204
“Landownership Concentration and the
Expansion of Education”, X. Tax Day, MPI
November 2013.
“Railroads and Growth in Prussia”, Economic
History Seminar, University of Mannheim, Mannheim, February 2014.
“The Evolution of Individual Property Rights
in the Process of Development”, XII. Tax Day,
July 2014.
in the Process of Development”, Meeting of
the Board of Trustees, MPI for Tax Law and
“Railroads and Growth in Prussia”, European
“Railroads and Growth in Prussia”, Annual
Congress of the Verein für Socialpolitik,
Helmut-Schmidt Universität, September
2014.
“The Political Economy of the Prussian
Three-class Franchise”, XIII. Tax Day, MPI
November 2014.
“Future Architecture of the Euro” Presentation and Panel Discussion, Joint Workshop
on the Euro Crisis, DIW Berlin, Berlin, January 2012.
in the Process of Development”, Economics
Brown Bag Seminar, University of Passau,
Passau, December 2014.
“Evolutionarily Stable In-Group Favoritism
and Out-Group Spite in Intergroup Conflict”,
Seminar Series of the SFB-TR15, Governance
and the Efficiency of Economic Systems,
Berlin, February 2012.
Changxia Ke
“Evolutionarily Stable In-Group Favoritism and Out-Group Spite in Intergroup
Conflict”, Tagung des Ausschusses für Bevölkerungsökonomik, Institut der deutschen
Wirtschaft, Cologne, February 2012.
“Are ‘Rockets and Feathers’ Caused by
Search or Informational Frictions?”, Seminar
Presentation, Monash University, Melbourne, Australia, January 2012.
“Alliances in the Shadow of Conflict”, Meeting of the SFB/TR 15, Governance and the
Efficiency of Economic Systems, Mannheim,
April 2012.
“Fight Alone or Together? The Need to
Belong”, Contest, Mechanisms and Experiments Conference, University of Exeter,
Devon, UK, April 2012.
“Are ‘Rockets and Feathers’ Caused by
Search or Informational Frictions?”, Seminar
Presentation, Düsseldorf Institute for Competition Economics, Heinrich Heine Universität Düsseldorf, Düsseldorf, May 2012.
“Fight Alone or Together? The Need to
Belong?”, Poster Presentation, Scientific
“Alliances in the Shadow of Conflict”,
Seminar Presentation, Universität Augsburg,
Augsburg, July 2012.
Kai A. Konrad
Comment on: Joachim Weimannns, “Wie
sinnvoll ist der klimapolitische Alleingang
Deutschlands?”, Die Zukunft der Energieversorgung, ifo-Institute and Bayerische
Akademie der Wissenschaften, Munich,
January 2012.
“Customs Compliance and the Power of
Imagination”, 1st FAU Workshop on Tax
Compliance, Friedrich-Alexander-Universität
Erlangen-Nürnberg, Nuremberg, March
2012.
“The Challenge of DeLeveraging and Overhangs of Debt II: The Politics and Economics
of Restructuring”, Lecture, Paradigm Lost
Conference, Institute for New Economic
Thinking, Berlin, April 2012.
“Unilateral Action and Negotiations about
Climate Policy”. Conference on New Directions in the Voluntary Provision of International Public Goods, Centre for European
Economic Research (ZEW), Mannheim, April
2012.
“Brothers in Arms – An Experiment on the
Alliance Puzzle”, MPI for Demographic Research, Rostock, April 2012.
“Haushaltsdisziplin in Deutschland unter
der Perspektive des Bremen-SaarlandSyndroms”, IGV-Conference: Auf dem Weg
zu nachhaltig ausgeglichenen Haushalten?
– Zwischenbilanz im zweiten Jahr grundgesetzlicher Schuldenbremsung, Freie Universität Berlin and Humboldt-Universität zu
Berlin, Berlin, May 2012.
“Das Schuldenproblem in der Eurozone –
die Rolle von Freiheit und Verantwortung”,
Keynote Speaker, WELT-Währungskonferenz,
Berlin, May 2012.
205
205
Alliance Puzzle”, Workshop on Political
Economy, Erasmus School of Economics,
Rotterdam, Netherlands, June 2012.
“Das Schuldenproblem in der Eurozone –
die Rolle von Freiheit und Verantwortung”,
quirin bank AG, Darmstadt, June 2012.
“Haushaltsdisziplin in Deutschland unter
der Perspektive des Bremen-Syndroms”,
Wirtschaftsrat der CDU e.V., Berlin, June
2012.
12th Jan Tinbergen Conference, DIW Berlin,
Berlin, June 2012.
“The Future of the Eurozone”, Association
of Managers and Executives of Aragon,
Zaragoza, Spain, July 2012.
Annual Congress of the International Institute of Public Finance, Technische Universität Dresden, Dresden, August 2012.
“Alliances: Joint Fighting and In-Group
Conflict”, 27th European Annual Congress,
Malaga, Spain, August 2012.
Alliance Puzzle”, Annual Congress of the
Verein für Socialpolitik, Göttingen, September 2012.
“Haushaltsdisziplin in Deutschland unter der
Perspektive des Bremen-Syndroms”, Panel:
Der Weg zu soliden Staatsfinanzen, Annual
Congress of the Verein für Socialpolitik, Göttingen, September 2012.
“Hanging Together or Being Hung Separately: The Strategic Power of Coalitions
where Bargaining Occurs with Incomplete
Information”, Munich-Tokyo-Conference on
Federal Public Economics, MPI for Tax Law
and Public Finance, Munich, September
2012.
“Staatsschulden ohne Sühne – Lösung durch
Inflation?”, 18th Colloquium of the Institut
für bankhistorische Forschung e.V., Frankfurt, September 2012.
206
“Hanging Together or Being Hung Separately: The Strategic Power of Coalitions where
Bargaining Occurs with Incomplete Information”, Microeconomics Seminar, University
of Zurich, Zurich, Switzerland, October 2012.
Alliance Puzzle”, Distinguished Lecture,
Hanse-Wissenschaftskolleg, Delmenhorst,
November 2012.
“Das Schuldenproblem in der Eurozone – die
Rolle von Freiheit und Verantwortung”, Conference, Familienunternehmer im Gespräch,
Baden-Baden, November 2012.
“Climate Policy Negotiations with Incomplete Information”, WWZ Research Seminar,
University of Basel, Basel, Switzerland,
November 2012.
“When the Weak Stand Together and the
Strong Stand Alone – on Group Formation
in Contests”, Research Seminar on Microeconomics, Universität Hamburg, Hamburg,
November 2012.
“When the Weak Stand Together and the
Strong Stand Alone – on Group Formation
in Contests”, Young Researchers Workshop
on Contests and Tournaments, Dortmund,
November 2012.
“Ursachen der Schuldenkrise und Konzepte
zu ihrer Bewältigung, Finanzkrise in der EU
und ihre Einflüsse auf die Türkei”, Istanbul
Kültür University, Istanbul, Turkey, November 2012.
“Bargaining with Incomplete Information:
the Strategic Power of Coalitions”, 6th
Workshop on Political Economy, CESifo/
Technische Universität Dresden, Dresden,
December 2012.
“Climate Policy Negotiations with Incomplete Information”, BC3-Research Seminar,
Basque Centre for Climate Change, Bilbao,
Spain, December 2012.
“Wie kann die Europäische Währungsunion
langfristig bestehen? Fünf Fragen”, ECONWATCH-Meeting, Berlin, February 2013.
“Climate Policy Negotiations with Incomplete Information”, THEMA, Université
Cergy-Pontoise, Cergy, France, March 2013.
“Alliances in the Shadow of Conflict”, Centre
d’Economie de la Sorbonne, Université Paris
1, Paris, France, March 2013.
Information”, ESI Mini Workshop on Experimental Economics III, MPI for Tax Law and
April 2013.
“Die Europäische Schuldenkrise – die Rolle
von Freiheit und Verantwortung”, Munich
Seminars, CESifo Group and Süddeutsche
Zeitung, Munich, June 2013.
PET International Meeting, Association for
Public Economic Theory, Lisbon, Portugal,
July 2013.
von Freiheit und Verantwortung“, Ökonomie
der Zukunft, UBS Deutschland AG and Institut Ökonomie der Zukunft, Frankfurt, July
2013.
“The European Debt Crisis: The Role of Freedom and Responsibility“, Storebrand, Berlin,
April 2013.
“Gibt es glaubwürdige Bündnisregeln?”,
Aspects of the Euro’s Future, Villa Vigoni,
Italy, July 2013.
von Freiheit und Verantwortung”, Johannes
Gutenberg University Mainz, Mainz, May
2013.
“Alliances in the Shadow of Conflict”, 13th
SAET Conference on Current Trends in Economics, MINES Paris Tech, Paris, France, July
2013.
“Deception Detection and the Role of
Self-Selection”, Öffentliche Finanzen und
“Tax Compliance: The Role of Deception and
Deception Detection Abilities and Self Selection”, Keynote Lecture, Conference on The
Shadow Economy, Tax Evasion and Governance, University of Münster, Münster, July
2013.
“Alliances in the Shadow of Conflict”, University of York, York, UK, May 2013.
“Deception Detection and the Role of SelfSelection”, Centre for Business Taxation
Seminar Series, University of Oxford, Oxford,
UK, May 2013.
“Die Europäische Schuldenkrise – die
Rolle von Freiheit und Haftung”, Dresdner
Vorträge zur Wirtschaftspolitik, Ifo Institute
Dresden, Dresden, June 2013.
Conflict: Theory and Evidence, Stockholm
School of Economics, Stockholm, Sweden,
June 2013.
“Endogenous Group Formation in Experimental Contests, Concentration on Conflict”,
Barcelona GSE Summer Forum, Institute for
Economic Analysis, Barcelona, Spain, June
2013.
“Brothers in Arms – Theory and Evidence
on Alliances”, Invited Lecture, 5th Singapore
Economic Review Conference, University of
Singapore, Singapore, August 2013.
“Deception Choice and Audit Design – The
Importance of Being Earnest”, MunichSydney-Conference on the Law and Economics of Taxation, MPI for Tax Law and Public
September 2013.
“Hanging Together or Being Hung Separately: The Strategic Power of Coalitions where
Bargaining Occurs with Incomplete Information”, Annual Congress of the Verein für
“The European Debt Crisis, its Development
and Possible Solutions”, 25th Anniversary
Conference, Academia Europaea, Breslau,
Poland, September 2013.
207
207
“Risk Taking and Taxation”, IV. Staff Retreat,
MPI or Tax Law and Public Finance, Kreuth,
September 2013.
“Sind ‘ehrliche Typen’ wirklich ehrlich? Ein
Experiment zur Steuerehrlichkeit”, Meeting
of the Chairmen of the Board of Trustees,
Max Planck Society, Munich, October 2013.
“Europe – Towards Renewed Growth? A
Public Finance Economist’s Perspective”,
NHH Summit 2013, Norwegian School of
Economics, Oslo, Norway, November 2013.
„Föderalismus und nachhaltige Finanzpolitik“, Invited Lecture, Ceremonial Act of
the Department of Economics, Technische
Universität Chemnitz, Chemnitz, November
2013.
Comment on: Klaus Schmidt, “Pay What You
Want as a Marketing Strategy in Monopolistic and Competitive Markets”, 17th Conference of the SFB/TR 15, Governance and the
Efficiency of Economic Systems, Tutzing,
November 2013.
“Sustainable Fiscal Policy in a Federation –
Implications for Europe”, Sixth Annual European Investment Conference, CFA Institute,
London, UK, November 2013.
“Fiskalunion und Bankenunion = Schuldenunion? Ein Fortschrittsbericht”, Conference
on Europa: Eindämmung der Krise, und
dann?, Centre for European Economic Research (ZEW) and Wirtschaftsdienst, Berlin,
November 2013.
„Haushaltsdisziplin im Föderalstaat“, BBAWVorlesungsreihe, Berlin-Brandenburgische
Akademie der Wissenschaften, Berlin,
December 2013.
“Werte: Lehren aus der Finanzkrise”, Second
Promerit Executive Forum, Promerit AG,
Frankfurt, January 2014.
“Deception, Choice and Audit Design – The
Importance of being Earnest”, Workshop on
Institutions, Games and Experiments, MPI of
Economics, Jena, February 2014.
208
“Old Money, the Nouveaux Riches and Brunhilde’s Marriage Dilemma”, Family Economics Workshop, Royal Halloway University of
London, UK, February 2014.
Brunhilde’s Marriage Dilemma”, Seminar
at the Centre for Studies in Economics and
Finance, Universita’ degli Studi di Napoli
Federico II, Naples, Italy, February 2014.
“Vote Buying with Unlimited Budgets”, XI.
Munich, March 2014.
Information”, Workshop on Federalism and
Regional Policy, University of Siegen, Siegen,
April 2014.
“Finanzwissenschaftliche Dimension”, 2.
Sitzung Arbeitskreis Ökonomie und Innovationsforschung, acatech, Munich, April 2014.
“Deception Choice and Audit Design”, Meeting on Experimental Economics / Neuro and
Social Sciences, Hanse-Wissenschaftskolleg,
Delmhorst, May 2014.
“Staatsschuldenabbau wie im Schlaf?”,
Keynote, WELT-Währungskonferenz, Berlin,
May 2014.
“Strategic Aspects in the Fight Against Tax
Havens”, Workshop on Tax Competition and
Public Policy, Center for Research in Economic Analysis, University of Luxembourg,
Luxembourg, May 2014.
“Deception Choice and Audit Design – The
Importance of Being Earnest”, Behavioral
Public Economics, Universität Wien, Austria,
June 2014.
“Deception Choice and Audit Design”, Lecture, University Hohenheim, Hohenheim,
July 2014.
“The Future of Fiscal Responsibility in the
Eurozone”, Forum for EU-US Legal-Economic
Affairs, The Mentor Group, Vienna, Austria,
September 2014.
“Fiscal Architecture in Europe: The Samaritan’s Dilemma?”, Keynote, Workshop
on Europe’s Crisis: The Conflict-theoretic
Perspective, University of Freiburg, Freiburg,
September 2014.
“NZZ-Podium: Europas «Weltmeister» – das
deutsche Momentum”, Neue Zürcher Zeitung, Berlin, October 2014.
“Targeted Campaign Competition, Loyal
Voters, and Supermajorities”, ESI Mini Workshop on Experimental Economics IV, MPI
for Tax Law and Public Finance and MPI of
Economics, Jena, October 2014.
“Targeted Campaign Competition, Loyal Voters, and Supermajorities”, Keynote, Workshop, NUI Maynooth University, Maynooth,
Ireland, November 2014.
“Brothers in Arms – Theory and Experimental Evidence on Alliances”, Australasian Public Choice Conference, Monash University,
Melbourne, Australia, December 2014.
“Deception Choice and Self Selection – The
Importance of Being Earnest”, Seminar, University of Osnabrück, Osnabrück, December
2014.
“Endogenous Group Formation in Contests”,
The Economics of Wars, École nationale de
la statistique et de l’analyse de l’information,
Rennes, France, December 2014.
Harald Lang
Comment on: Yasmin Holm, “Gewinnermittlung bei Betriebsstätten”, IV. Staff Retreat,
September 2013.
“A Glance into the Tunnel – Beliefs vs.
Relative-Income Considerations”, ESI Mini
Workshop on Experimental Economics IV,
MPI for Tax Law and Public Finance and MPI
of Economics, Jena, October 2014.
“A Glance into the Tunnel – Beliefs vs.
Relative-Income Considerations”, ESI MiniWorkshop on Experimental Economics II”,
University of Innsbruck, Innsbruck, Austria,
October 2014.
“Corporate Tax Avoidance in a Principal
Agent Model”, 7th FFF Stipend-ResearchWorkshop, Social Science Research Center
Berlin (WZB), Berlin, February 2012.
“Multitasking in Corporate Tax Evasion”, VIII.
Munich, March 2013.
“Financial Contracting with Tax Evaders”,
Public Economics Seminar at the Chair of
Prof. Haufler, Ludwig-Maximilians-Universität München, Munich, October 2013.
“Financial Contracting with Tax Evaders”, 12.
Finanzwissenschaftliches Seminar, Social Science Research Center Berlin (WZB), Berlin,
December 2013.
“Optimal Auditing with Overconfident Taxpayers”, Brownbag Seminar at the Chair of
Prof. Schöb, Freie Universität Berlin, Berlin,
December 2013.
PET 2014 15th International Conference on
Public Economics, University of Washington,
Seattle, USA, July 2014.
70th Annual Congress of the International
Institute of Public Finance, Redesigning the
Welfare State for Aging Societies, University
of Lugano, Lugano, Switzerland, August.
Annual Congress of the Verein für Socialpolitik, Helmut-Schmidt Universität, Hamburg,
September 2014.
Rhea Molato
“Public Debt and the Threat of Secession”, V.
Munich, January 2012.
209
209
“Public Debt and the Threat of Secession”,
Public Economics Seminar, Ludwig-Maximilians-Universität München, Department of
Economics, Munich, May 2014.
“Measuring Bribery from Micro Data”,
Ph.D. Seminar, MPI for Tax Law and Public
Finance, Munich, May 2014.
Florian Morath
Alliance Puzzle”, Annual Congress of the
International Institute of Public Finance,
August 2012.
“Alliances in the Shadow of Conflict”, European Congress of the Economic Science
Association, Universität zu Köln, Cologne,
September 2012.
“The Taxation of Financial Transactions with
Endogenous Information”, VII. Tax Day, MPI
September 2012.
Finance, Munich, October 2012.
“Alliances in the Shadow of Conflict”, CESifo
Area Conference on Behavioural Economics,
CESifo Group, Munich, November 2012.
Conference of the SFB/TR 15, Governance
and the Efficiency of Economic Systems,
Caputh, November 2012.
“Alliances in the Shadow of Conflict”, Workshop on Contests: Experiments and Theory,
January 2013.
“Endogenous Group Formation in Experimental Contests”, Innsbruck-Munich Conference on Public Economics, University of
Innsbruck, Innsbruck, Austria, March 2013.
“Alliances in the Shadow of Conflict”, Universität Wien, Vienna, Austria, March 2013.
210
“Online Shopping”, VIII. Tax Day, MPI for
Tax Law and Public Finance, Munich, March
2013.
“Alliances in the Shadow of Conflict”, International Conference on Cooperation or Conflict, Wageningen, Netherlands, May 2013.
“The Taxation of Bilateral Trade with Endogenous Information”, University of Cologne,
Cologne, June 2013.
University of Augsburg, Augsburg, June
2013.
Association for Public Economic Theory,
International Meeting, Lisbon, Portugal, July
2013.
Annual Conference, Taormina, Italy, August
2013.
CESifo Area Conference on Energy and
Climate Economics, CESifo Group, Munich,
October 2013.
“The Taxation of Bilateral Trade with Endogenous Information”, 17th Conference of the
Economic Systems, Tutzing, November 2013.
“Endogenous Group Formation in Experimental Contests”, Workshop on Norms, Actions, Games 2014, King’s College London,
London, UK, April 2014.
“The Taxation of Bilateral Trade with Endogenous Information”, CESifo Area Conference
on Public Sector Economics, CESifo Group,
Munich, April 2014.
“Endogenous Group Formation in Experimental Contests”, 2014 Political Economy
Workshop, Catholic University, Milan, Italy,
May 2014.
“The Taxation of Bilateral Trade with
Endogenous Information”, PET 2014 15th
International Conference on Public Economics, University of Washington, Seattle, USA,
July 2014.
“The Taxation of Bilateral Trade with Endogenous Information”, 70th Annual Congress of
the International Institute of Public Finance,
Redesigning the Welfare State for Aging
Societies, University of Lugano, Lugano,
Switzerland, August 2014.
Annual Congress of the Verein für Socialpolitik, Helmut-Schmidt Universität, Hamburg,
September 2014.
Seminar, Technische Universität Dortmund,
Dortmund, October 2014.
Salmai Qari
“Methods for Clustered Binary Response
Data: A Power Comparison”, Workshop on
Empirical Methods in Public Finance, MPI
March 2012.
“Durable Consumption Goods and Happiness”, Royal Economic Society, Annual
Conference, Cambridge, UK, March 2012.
“Compliance and Beliefs: Appearance vs.
Performance”, Poster Presentation, Scientific
“Compliance and Beliefs: Appearance vs.
Performance”, VI. Tax Day, MPI for Tax Law
Imagination”, Annual Conference of the
August 2012.
“Do Second-Order Beliefs Work?”, ESI Mini
Workshop on Experimental Economics II,
October 2012.
“Compliance and the Subjective Audit
Probability”, Department of Public Finance,
University of Innsbruck, Innsbruck, January
2013.
“Deception Detection and the Role of SelfSelection”, VIII. Tax Day, MPI for Tax Law and
Public Finance, Munich, March 2013.
“Discussion of ‘Short- and Long-Term Effects of Free Care Services for Mothers and
Infants’”, Augsburg Workshop on the Economics of Health Behaviors and Prevention,
Augsburg University, Augsburg, December
2013.
“Deception Choice and Self-Selection – The
Importance of Being Earnest”, University of
Siegen, Siegen, January 2014.
Tim Stolper
“The Role of Customer Coordination in the
Fight Against Tax Havens”, IV. Staff Retreat,
September 2013.
“Coordination and the Fight Against Tax
Havens”, Workshop on Understanding Tax
Havens, MPI for Tax Law and Public Finance
and Norwegian School of Economics, Munich, January 2014.
Havens”, Seminar with Bruno Frey, MPI for
Tax Law and Public Finance, Munich, March
2014.
Imagination”, European Economic Association Annual Congress, Malaga, Spain, August
2012.
Havens”, Tax Policy and the Activities of Multinational Firms, Eberhard Karls Universität
in Tübingen, Tübingen, June 2014.
“Do Second-Order Beliefs Work?”, VII. Tax
Day, MPI for Tax Law and Public Finance,
Munich, September 2012.
Discussion on “Great Expectations: Income
Expectations, Income Realizations, and
Attitudes Towards Redistribution”, EDGE
Jamboree, University of Copenhagen, Copenhagen, Denmark, September 2014.
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211
“Coordination and the Fight Against Tax Havens”, Ph.D. Seminar, University of Copenhagen, Copenhagen, Denmark, October 2014.
“Third-Party Punishment: Retribution or
Deterrence”, Lunch Seminar at ETH Zürich,
Zurich, Switzerland, October 2012.
“Coordination and the Fight Against Tax Havens”, ESI Mini Workshop on Experimental
Economics IV, MPI for Tax Law and Public
Finance and MPI of Economics, Jena, October 2014.
“Delegation in the Provision of Global Public
Goods”, Frankfurt School of Finance and
Management, Frankfurt, October 2012.
Fangfang Tan
“Who Acts More Like a Game Theorist?
Group and Individual Play in a Sequential
Market Game and the Effect of the Time
Horizon”, Royal Economic Society, Annual
Conference, Cambridge, UK, March 2012.
“Can Strategic Uncertainty Help Deter Tax
Evasion? – An Experiment on Auditing
Rules”, Deception, Incentives and Behaviour
Symposium, San Diego, USA, April 2012.
“Who Approves Punishment? A Comparison
of Groups and Individuals in Social Dilemmas”, International ESA Conference, New
York, USA, June 2012.
“Delegation in the Provision of Global
Public Goods”, Micro Workshop, LudwigMaximilians-Universität München, Munich,
July 2012.
“Delegation in the Provision of Global
Public Goods”, Economic Colloquia Seminar,
University of Amsterdam, Amsterdam, Netherlands, August 2012.
“Who Approves Punishment? A Comparison
of Groups and Individuals in Social Dilemmas”, Tiber Symposium on Psychology and
Economics, Tilburg, Netherlands, August
2012.
Goods”, Economics Science Association
European Conference, Cologne, September
2012.
Goods”, Behavioural and Experimental Seminar, University of Zurich, Zurich, Switzerland,
October 2012.
212
“‘Success Breeds Success’ or ‘Pride Goes
Before a Fall’? Individuals and Teams in the
Best-of-Three Contests”, Micro Workshop,
Munich, October 2012.
Best-of-Three Contests”, ESI Mini Workshop
on Experimental Economics II, MPI for Tax
Law and Public Finance, Munich, October
2012.
Goods”, ESA North American Meeting, Tucson, USA, November 2012.
Deterrence”, ICES Brownbag Lunch Seminar,
George Mason University, Washington DC,
USA, November 2012.
Best-of-Three Contests”, Workshop on Contests: Experiments and Theory, MPI for Tax
Law and Public Finance, Munich, January
2013.
Goods”, Innsbruck-Munich Conference on
Public Economics, University of Innsbruck,
Innsbruck, Austria, March 2013.
Best-of-Three Contests”, 2013 Conference
on Tournaments, Contests and Relative Performance Evaluation, Fresno Center of the
University of California, Fresno, USA, March
2013.
Best-of-Three Contests”, Brownbag Lunch
Seminar at University of Pittsburgh, Pittsburgh, USA, March 2013.
Deterrence”, ESI Mini Workshop on Experimental Economics III, MPI for Tax Law and
April 2013.
Before a Fall’? Individuals and Teams in
the Best-of-Three Contests”, Experimental
Economics Seminar Series, University of
California at Santa Cruz, Sant Cruz, USA,
April 2013.
Best-of-Three Contests”, Seminar, University
of San Francisco, San Francisco, USA, April
2013.
Goods”, IX. Tax Day, MPI for Tax Law and
Public Finance, Munich, May 2013.
Deterrence”, The Bay Area Behavioral and
Experimental Economics Workshop, University of San Francisco, San Francisco, USA,
May 2013.
Before a Fall’? Individuals and Teams in
the Best-of-Three Contests”, VCEE Seminar
Series, University of Vienna, Vienna, Austria,
May 2013.
Best-of-Three Contests”, SABE Session at the
Western Economic Association International
Meeting, Seattle, USA, June 2013.
“Justification and the Legitimate Punishment”, ESA World Meeting, Zurich, Switzerland, July 2013.
Best-of-Three Contests” ESA North American
Meeting, Santa Cruz, USA, October 2013.
“Liberty and Responsibility in Polycentric
Circles: The Ostrom Legacy”, ESA North
American Meeting, Santa Cruz, USA, October 2013.
Goods”, Seminar Presentation, University of
Vermont, Burlington, USA, January 2014.
Deterrence”, Seminar Presentation, University of Pennsylvania, Philadelphia, USA,
February 2014.
Best-of-Three Contests”, Seminar Presentation, California State University, San Marcos,
USA, February 2014.
Best-of-Three Contests”, University of British
Columbia, Vancouver, Canada, April 2014.
Best-of-Three Contests”, Presentation, Yahoo! Labs, Sunnyvale, USA, April 2014.
Deterrence”, International Society of Justice
Research (ISJR) Meeting, New York, USA,
June 2014.
Goods”, PET 2014 15th International Conference on Public Economics, University of
Washington, Seattle, USA, July 2014.
Best-of-Three Contests”, INFORMS Annual
Meeting, Minneapolis, USA, October 2013.
Best-of-Three Contests”, California State
University East Bay, Hayward, USA, October
2013.
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213
IIIEditorial Services
IV Activities and Memberships
Kai A. Konrad
Sabine Aresin
Co-editor: Journal of Public Economics.
Member, European Economic Association
(EEA).
Associate Editor: CESifo Economic Studies.
Associate Editor: Economics of Governance.
Associate Editor: The Geneva Risk and Insurance Review.
Member of Editorial Board: Journal of Conflict Resolution.
Associate Editor: Journal of Population
Economics.
Member of Editorial Board: German Economic Review.
Member of Editorial Board: World Tax Journal.
Member, International Institute of Public
Finance (IIPF).
Anne-Kathrin Brosert
Elected Ph.D. Representative, from 20122014.
(EEA).
Finance (IIPF).
Member, Verein für Socialpolitik (VfS).
Series Co-editor: Finanzwissenschaftliche
Schriften.
Nadja Dwenger
Co-editor: Beiträge zur Finanzwissenschaft.
Affiliate, CESifo Research Network.
Co-editor: Social Science Research Network/
Max Planck Institute for Tax Law & Public
Finance Research Paper Series.
Member, American Economic Association
(AEA).
International Institute of Public Finance
(IIPF), Member.
Member, National Tax Association.
Member, Collaborative Research Center
(SFB) Transregio 15.
Member, Berlin Network of Labor Market
Research.
Elected Scientific Staff Employee to the
Human Sciences Section and the Scientific
Council of the Max Planck Society, until June
2014.
2014.
214
May Elsayyad
(EEA).
Finance (IIPF).
Aart Gerritsen
(EEA).
Finance (IIPF).
Member, Royal Economic Society (RES).
2014.
Luisa Herbst
Member, Economic Science Association
(ESA).
(EEA), in 2013.
Finance (IIPF), in 2013.
Elected Member of the Institute’s Commitee, until January 2014.
Michael Hilmer
Member, American Economics Association
(AEA).
Elected Member of the Institute’s Commitee, until January 2014.
Erik Hornung
Research Fellow, CAGE (Centre for Competitive Advantage in the Global Economy).
(EEA).
Member, American Economic Association (AEA).
Member, Economic History Association
(EHA).
Kai A. Konrad
Member of the Berlin-Brandenburgische
Akademie der Wissenschaften, since 2014.
Member of the Academia Europaea, since
2013.
Member of the German National Academy
of Sciences Leopoldina, since 2013.
Member of the National Academy of Science and Engineering (acatech), since 2012.
Honorary Professor, School of Business and
Economics, Freie Universität Berlin, since
2011.
Honorary Professor, Department of Economics, Ludwig-Maximilians-Universität
München, since 2009.
WZB Fellow, Social Science Research Center
Berlin (WZB), since 2013.
Research Professor, Social Science Research
Center Berlin (WZB), 2009–2012.
Research Professor, Ifo Institute Munich,
since 2002.
Chairman of the Council of Scientific Advisors to the Federal Ministry of Finance (Wissenschaftlicher Beirat beim Bundesministerium der Finanzen), 2011–2014.
Member of the Council of Scientific Advisors
to the Federal Ministry of Finance, since
1999.
215
215
Member of the Scientific Advisory Board,
Kiel Institute for the World Economy (IfW),
Kiel, since 2014.
Member of the Scientific Council, Bruegel,
since 2012.
Member of the Scientific Advisory Board,
Rheinisch-Westfälisches Institut für
Wirtschaftsforschung e.V. (RWI), since 2011.
Member of the Scientific Advisory Council
of the Munich Center of Governance, Communication, Public Policy and Law (MCG),
2009-2012.
Member of the Scientific Advisory Council,
Centre for European Economic Research
(ZEW), since 2000.
Member of MaxNetAging, since 2009.
International Research Fellow, Oxford University Centre for Business Taxation, since
2009.
CESifo Area Director, Research Area “Employment and Social Protection”, since 2004.
International Affiliate, Center for the Study
of Democracy at UCI, since 2003.
Research Fellow, Institute for the Study of
Labor (IZA), since 1999.
CESifo Research Network Fellow, since 1999.
Research Fellow, Centre for Economic Policy
Research (CEPR), since 1994.
Member of the Board of Trustees,
ECONWATCH, since 2012.
Member of the Scientific Council,
Wirtschaftsdienst, since 2011.
Founding Member of the “Ökonomenstimme”, since 2010.
Member of the Board of the Research
Programme “Strengthening Efficiency and
Competitiveness in the European Knowledge Economy” (SEEK), Centre for European
Economic Research (ZEW), since 2010.
Member of the Project “Anpassungsstrategien in der Klimapolitik”, National Academy
216
of Science and Engineering (acatech),
2011–2012.
Member of the E.ON Ruhrgas Scholarship
Committee, 2004–2012.
(AEA).
(EEA).
Member, International Institute for Public
Finance (IIPF).
Florian Morath
International Institute of Public Finance
(IIPF), Member
Salmai Qari
Member, International Institute for Public
Finance (IIPF).
Fangfang Tan
(AEA).
Finance (IIPF).
Member, Economic Science Association
(ESA).
Member, Western Economic Association
(WEA).
Member, Royal Economic Society (RES).
VTeaching
Sabine Aresin
Classes for the Lecture “Mathematische
Methoden der VWL”, Ludwig-MaximiliansUniversität München, Munich, Winter Term
2014/15.
May Elsayyad
Tutorial for the Lecture “Internationale Finanzpolitik”, Ludwig-Maximilians-Universität
Luisa Herbst
Thomas Daske
Classes for the Lecture “Topics on International Public Finance”, Ludwig-MaximiliansUniversität München, Munich, Winter Term
2012/13.
Classes for the Lecture “Analysis for Computer Science”, Technische Universität
Erik Hornung
Classes for the Lecture “Analysis 2”, Technische Universität München, Munich, Summer
Term 2012.
Classes for the Lecture „Spieltheorie“
(“Game Theory“), Ludwig-MaximiliansUniversität München, Munich, Winter Term
2012/13.
Term 2013.
Vacation Course “Analysis 2”, Technische
Universität München, Munich, Summer
Term 2013.
Classes for the Lecture “Analysis 1”, Technische Universität München, Munich, Winter
Term 2013/14.
Term 2014.
Vacation Course “Analysis 2”, Technische
Universität München, Munich, Summer
Term 2014.
Nadja Dwenger
Empirical Public Economics, Lecture and
Tutorial for Master and Ph.D. Students,
Lecture “Culture and Institutions in Economic History”, Ludwig-Maximilians-Universität
Kai A. Konrad
Ph.D. Seminar, Ludwig-Maximilians-Universität München / MPI for Tax Law and Public
Finance, Munich, Winter Term 2011/12.
Lecture “Internationale Finanzpolitik”,
Finance, Munich, Summer Term 2012.
Lecture “Internationale Finanzpolitik”, Freie
Universität Berlin, Berlin, Summer Term
2013.
Lecture “Topics in International Public
Finance”, Ludwig-Maximilians-Universität
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217
Classes for the Lecture “Behavioral Economics”, Ludwig-Maximilians-Universität
Lecture “International Public Economics”,
Lecture “Experimental Economics”, University of Califorina, Santa Cruz, USA, Fall Term
2014.
VI Awards and Prizes
Florian Morath
Nadja Dwenger
Lecture “Public Economics”, Columbia University, New York, USA, Spring Term 2012.
Best Paper Award of the Vereinigung der
Freunde des DIW Berlin e.V. (2 500 Euro) in
2013.
Salmai Qari
Award of the Dr. Theo und Friedl Schöller
Foundation (20 000 Euro) in 2013.
Lecture “Einführung in verteilungsfreie
Verfahren”, Ludwig-Maximilians-Universität
Lecture “Einführung in verteilungsfreie
Verfahren”, Ludwig-Maximilians-Universität
Research Grant, Research Council of Norway
(€ 3 700).
Lecture ”Econometrics (Master)”, Hochschule für Wirtschaft und Recht Berlin,
Berlin, Summer Term 2014
May Elsayyad
Lecture “Empirical Economic Research and
Introductory Econometrics (Bachelor)”,
Hochschule für Wirtschaft und Recht Berlin,
Berlin, Summer Term 2014, Winter Term
2014/15
Ibn Khaldun Prize 2012, granted to young
economists by the Middle East Economic
Association.
Aart Gerritsen
Lecture “Statistics (Bachelor)”, Hochschule
für Wirtschaft und Recht Berlin, Berlin, Winter Term 2014/15.
Nominated for the KVS-medal for the best
Ph.D. thesis in Economics, awarded every
three years by the Royal Dutch Society for
Economics 2014.
Tim Stolper
Erik Hornung
Tutorial for the Lecture “International Public
Economics”, Ludwig-Maximilians-Universität
Prize for Young Academics of the Leibniz
Association in 2013.
Fangfang Tan
Lecture “Behavioural Economics”, LudwigMaximilians-Universität München, Munich,
218
Schmölders Prize 2014, granted to the best
paper by the Verein für Socialpolitik (VfS).
Kai A. Konrad
Elected as a Member to the National Academy of Science and Engineering (acatech) in
2012.
Elected as a Member to the German National Academy of Sciences Leopoldina in 2013.
VII Habilitation and Ph.D. Projects
Elected as a Member to the Academia Europaea in 2013.
Kai A. Konrad
Elected as a Member to the Berlin-Brandenburgische Akademie der Wissenschaften in
2014.
Harald Lang
Alumni Prize for Young Economists of the
Müchner Volkswirte Alumni-Club e.V in
2013.
Salmai Qari
Offer for a Professorship in Mathematical
Economics and Quantitative Methods,
Berlin School of Economics and Law, in 2013
(declined).
Offer for a Professorship in Econometrics,
Berlin School of Economics and Law, in 2013
(accepted).
E.ON mobility grant for a research visit to
Department of Economics, Norwegian Business School (BI), Oslo, Norway in 2014.
Dr. Nadja Dwenger: Institutional Framework
and Individual Response – New Perspectives
on Public Finance.
Aart Gerritsen: Essays in Public Economics.
Dr. Erik Hornung: Essays in Public Economics.
Dr. Florian Morath: Essays in Public Economics.
2. Ph.D. Theses
Sabine Aresin: Essays in Public Finance.
Anne-Kathrin Bronsert: Essays in Public
Finance.
Kai Brückerhoff: Essays in Public Finance.
Thomas Daske: Essays in Public Finance.
May Elsayyad: Fighting Tax Havens and Climate Change, November 2012 (completed).
Luisa Herbst: Essays on Contests Experiments.
Michael Hilmer: Taxing Manager’s Bonuses:
Essays on the Implications of Bonus Taxation.
Harald Lang: Essays in Public Finance.
Philipp Meyer-Brauns: Essays in Public and
Corporate Finance, January 2015 (completed).
Rhea Molato: Differences in the Public Sector: Essays on Secession Threats and Wage
Differentials.
Sven Arne Simon: Essays in Public Finance.
Tim Stolper: Essays in Public Finance.
Salmai Qari: Tax Avoidance, Household Formation and Inequality, June 2012 (completed).
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219
CEvents, Conventions, and Commit tees
IEvents of the Department
1. Conferences and Other Events
V. Tax Day, MPI for Tax Law and Public Finance, Munich, 10-11 January 2012.
7 FFF Stipend-Research-Workshop, Social
Science Research Center Berlin (WZB), Berlin, 1 February 2012.
th
Munich, 15-16 March 2012.
Finance, Schliersee, 6-8 May 2012.
VI. Tax Day, MPI for Tax Law and Public
Finance, Munich, 23 May 2012.
Workshop on Taxation and Redistribution,
6 June 2012.
8th FFF Stipend-Research-Workshop, Social
Science Research Center Berlin (WZB), Berlin, 22 June 2012.
Munich-Tokyo-Conference on Federal Public
Economics, MPI for Tax Law and Public
Finance, Munich, September 2012.
Workshop on Contests: Experiments and
Theory, MPI for Tax Law and Public Finance,
Munich, 9-10 January 2013.
Innsbruck-Munich Conference on Public Economics, MPI for Tax Law and Public Finance,
and University of Innsbruck, Innsbruck,
Austria, 12 March 2013.
Allocation of the Tax Base, MPI for Tax Law
and Public Finance, Oxford University Centre
for Business Taxation, Saïd Business School,
Oxford, UK, 18 March 2013.
Finance, Munich, 20-21 March 2013.
Economics III, MPI for Tax Law and Public
Finance and MPI of Economics, Jena, 8-9
April 2013.
Öffentliche Finanzen und Politische Ökonomie I, MPI for Tax Law and Public Finance,
Joint Seminar with Bruno Frey, Schliersee,
12-14 May 2013.
IX. Tax Day, MPI for Tax Law and Public Finance, Munich, 13-14 August 2013.
VII. Tax Day, MPI for Tax Law and Public
Finance, Munich, 13 September 2012.
Finance, Kreuth, 23-24 September 2013.
Finance, Munich, 22-23 October 2012.
Advances on the Political Economy of Conflict and Redistribution II, MPI for Tax Law
and Public Finance, Social Science Research
Center (WZB), Norwegian Centre of Excellence on Equality, Social Organization, and
Performance at the University of Oslo, Berlin, 28-29 October 2013.
The End of Federalism?, Conference, Social
Science Research Center Berlin (WZB), Berlin, 29-30 October 2012.
220
Shaping the Fiscal Institutions of Europe,
Conference, Federal Ministry of Finance,
Berlin, 21 November 2012.
Finance, Munich, 4-5 November 2013.
X. Tax Day, MPI for Tax Law and Public Finance, Munich, 26-27 November 2013.
Workshop on Understanding Tax Havens,
22-23 January 2014.
XI. Tax Day, MPI for Tax Law and Public Finance, Munich, 18-19 March 2014.
Workshop on Öffentliche Finanzen und
Frey and Marcel Thum, Munich, 17-18 June
2014.
XII. Tax Day, MPI for Tax Law and Public
Finance, Munich, 8-9 July 2014.
2.MPI Lecture Series
Bruno Jeitziner, Professor, University of
Freiburg, Steuerpolitik im Spannungsfeld der
Interessen, 17 January 2012.
Bruno S. Frey, Professor, University of
Zurich, Switzerland, Glücksforschung und
Manipulationsprinzip, 21 May 2012.
Robin Boadway, Professor, Queen’s University, Canada, Tax Policy for the 21st Century:
Lessons from the Mirrlees and Henry Reviews, 10 July 2012.
Dr. Dr. Christoph M. Schmidt, Professor, Rheinisch-Westfälisches Institut
für Wirtschaftsforschung, Wachstum,
Wohlstand, Lebensqualität: Ergebnisse der
Bundestags-Enquete, 28 May 2013.
Workshop on Contest Theory and Political
Competition, MPI for Tax Law and Public
Finance, Munich, 4-5 September 2014.
Thomas A. Gresik, Professor, University of
Notre Dame, USA, The Economic Implications of Choosing Between Separate Accounting and Formula Apportionment, 10
July 2013.
ESI-Mini Workshop on Experimental Economics IV, MPI for Tax Law and Public Economics and MPI of Economics, Jena, 21-22
October 2014.
Jan K. Brueckner, Professor, University of
California in Irvine, USA, Negative Campaigning in a Probabilistic Voting Model, 11
September 2013.
Innsbruck-Munich Conference on Public
Economics and University of Innsbruck,
Innsbruck, Austria, 27 October 2014.
Dr. Ronnie Schöb, Professor, Freie Universität Berlin, Geld macht doch glücklich! Die
ökonomische Glücksforschung auf dem
Prüfstand, 15 July 2014.
MGSE Open Day Event, MPI for Tax Law and
Public Economics, Munich, 5 November
2014.
Dr. Michael Ahlheim, Professor, Universtität
Hohenheim, The Economic Valuation of
Environmental Improvements and the Role
of Ethnicity and Culture – An Example from
Southwest China, 5 August 2014.
XIII. Tax Day, MPI for Tax Law and Public Economics, Munich, 11-12 November 2014.
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3. Guest Lectures
Carlo Prato, Northwestern University, USA,
Dynamic Political Distortions under Alternative Constitutional Settings, 31 January
2012.
Luca Corazzini, Associated Professor, University of Padova, Italy, Too Many Charities?
Insights from an Experiment with Multiple
Public Goods and Contribution Tresholds, 13
August 2013.
Raphael Parchet, Université de Lausanne,
Switzerland, Culture and Taxes Towards
Identifying Tax Competition, 31 January
2012.
Thomas Moutos, Professor, Athens University of Economics and Business, Greece,
Monopoly, Government Inefficiency, and
Public Provision of Private Goods, 13 August
2013.
Niels Johannesen, University of Copenhagen, Denmark, The End of Bank Secrecy? An
Evaluation of the G20 Tax Haven Crackdown,
22 February 2012.
Aart Gerritsen, Erasmus University Rotterdam, Netherlands, Optimal Taxation when
People Do Not Maximize Well-Being, 13
August 2013.
Pohan Fong, City University of Hong Kong,
China, Agenda Setting with Endogenous
Agenda Setters, 14 May 2012.
Dr. Axel Möhlmann, Leibniz Universität
Hannover, The Return on Tax Preparation
Expenses, 14 August 2013.
Bob Chirinko, University of Illinois at Chicago, USA, Tax Competition among U.S.
States: Racing to the Bottom or Riding on a
Seesaw?, 15 May 2012.
Pierre Boyer, Junior Professor, University of
Mannheim, Efficiency, Welfare, and Political
Competition, 14 August 2013.
Andreas Nicklisch, University of Hamburg,
Transparency & Accountability: Substitutes
or Complements?, 21 June 2012.
Trond E. Olsen, Norwegian School of Economics, Norway, Incentive Provision when
Contracting is Costly?, 25 July 2012.
Ami Glazer, Professor, University of California in Irvine, USA, Profit-Maximizing NonGovernmental Organizations, 6 March 2013.
Jenny Simon, Stockholm School of Economics, Sweden, Imperfect Financial Markets as
a Commitment Device for the Government,
20 March 2013.
Luca Salvadori, University of Barcelona,
Spain, Empirical Evidence on Horizontal
Competition in Tax Enforcement, 21 March.
Raul Fabella, Professor, UP School of
Economics, Philippines, The Robust Nash
Equilibrium and Equilibrium Selection in
Coordination Games, 29 May 2013.
Dr. Loukas Balafoutas, Professor, University
of Innsbruck, Austria, The Hidden Costs of
Tax Evasion, 26 November 2013.
Dr. James Rockey, Assistant Professor, University of Leiceister, United Kingdom, Party
Formation and Competition, 27 November
2013.
Dr. Sabine Flamand, Nova School of Business and Economics, Portugal, Partial Decentralisation as a Way to Avoid Secessionist
Conflict, 27 November 2013. Ayse Gül Mermer, Ph.D., University of
Tilburg, Netherlands, Contests with Expectation-Based Loss-Averse Players, 15 January
2014.
Dr. Kiryl Khalmetski, University of Frankfurt,
The Hidden Value of Lying: Evasion of Guilt
in Expert Advice, 15 January 2014.
Irem Guceri, University of Oxford, UK, Tax
Incentives and R&D: An Evaluation of the
2002 UK Reform Using Micro Data, 15 January 2014.
Pierre Boyer, Ph.D., University of Mannheim, Welfare Programs and Motivation Bias
of Social Workers, 18 March 2014.
222
Dr. Rafael Aigner, MPI for Collective Goods,
Taxing Wall Street: The case of boring banking, 18 March 2014.
Rajshri Jayaraman, Ph.D., Professor, European School of Management and Technology,
Productive response to a contract change,
18 March 2014.
Dr. Regine Oexl, University of Innsbruck,
Austria, Distributional Preference Types and
Ego Depletion, 19 March 2014.
Sven Arne Simon, University of Mannheim,
Seminar Talks on Financial Development and
Economic Growth, 24 April 2014.
Susanne Wildgruber, Ludwig-MaximiliansUniversität München, Seminar Talk on
Financial Sector Development in Latin
America-the Influence of Political Factors, 20
May 2014.
Steeve Mongrain, Professor, Simon Fraser
University, Canada, Crime, Wealth, and
Protection: Theory and Canadian Evidence,
10 June 2014.
Vai-Lam Mui, Professor, Monash University,
Australia, Identity and Cooperation in the
Inter-Group Prisoner’s Dilemma, 10 June
2014.
Dr. Ronnie Schöb, Professor, Freie Universität Berlin, Climate Change and Psychological Adaptation: A Behavioral Environmental
Economics Approach, 10 July 2014.
David Agrawal, Ph.D., Professor, University
of Georgia, USA, State Tax Differentials,
Cross-border Commuting, and Commuting
Times in Multi-State Metropolitan Areas, 10
July 2014.
Dr. Rupert Sausgruber, Professor, Univeristy,
of Vienna, Austria, Experimental Evidence
on Motivational Gender Sorting into Jobs,
11-12 November 2014.
Dr. Nils aus dem Moore, Rheinisch-Westfälisches Institut für Wirtschaftsforschung,
Taxes and Corporate Financing Decisions
– Evidence from the Belgian ACE Reform,
11-12 November 2014.
Blake Allison, University of California, USA,
Do Players Prefer to Bargain Non-cooperatively in the Shadow of Conflict?, 11-12
November 2014.
Dr. Bettina Klose, University of Zurich,
Switzerland, Moderating Alliances, 11-12
November 2014.
Wolfgang Leininger, Professor, Technische
Universität Dortmund, Asymmetric Lottery
Contests with Heterogeneous Agents and
the Provision of Public Goods, 24 June 2014.
Dan Kovenock, Professor, Chapman University, USA, Dynamic Behavior and Player
Types in Majoritarian Multi-Battle Contests,
26 August 2014.
Rick van der Ploeg, Professor, University of
Oxford, UK, Climate Tipping and Economic
Growth: Precautionary Saving and the Social
Cost of Carbon, 19 November 2014.
Justin Valasek, Ph.D., Social Science Research Center Berlin (WZB), Berlin, Reforming an Institutional Culture of Corruption:
Collective Reputation, Signaling, and Public
Sector Motivation, 9 July 2014.
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223
4. Ph.D. Lectures
Michael Hilmer, Bonuses and Limited Deductibility, 18 January 2012.
Thomas Daske (with Mauritz von Einem),
Profit Shifting and Tax Competition, 28
February 2012.
Luisa Herbst, Alliances in Three-Party Contests, 4 April 2012.
Michael Hilmer, Incentive Contracting
under Limited Liability and Limited Deductibility of Bonuses, 4 April 2012.
224
Thomas Daske, Friends and Foes at Work:
Assigning Teams in a Social Network, Progress Report, 15 January 2013.
Philipp Meyer-Brauns, Multitasking in Corporate Tax Evasion, 15 January 2013.
Rhea Molato, Conditional Cash Transfers
and Household Consumption in the Philippines, 6 February 2013.
Anne-Kathrin Bronsert, The Nouveaux Riches, Old Money and Conspicuous Consumption, Progress Report, 19 February 2013.
Sabine Aresin, Cross Border Abatement and
its Welfare Effects, 2 May 2012.
Philipp Meyer-Brauns, Financial Contracting
with Tax Evaders, Progress Report, 16 April
2013.
Sabine Aresin, Cross Border Abatement and
its Welfare Effects, Progress Report, 20 June
2012.
with Tax Evaders, Progress Report, 30 April
2013.
Thomas Daske, Public Goods and Reference-group Dependent Social Preferences,
20 June 2012.
Luisa Herbst, Does the Balance of Power
Matter for Resource Wasteful Conflict?, 30
April 2013. Luisa Herbst, When the Weak Stand Together and the Strong Stand Alone – On Alliance Formation in Contests, 3 July 2012.
Anne-Kathrin Bronsert, Old Money, the
Nouveaux Riches and Brunhilde’s Marriage
Dilemma, 22 May 2013.
Michael Hilmer, Fiscal Treatment of Managerial Compensation – a Welfare Analysis, 3
July 2012.
Harald Lang, The Political Economy of
Reform – Opaque Policy Decisions and Information Lobbying, 22 May 2013.
Michael Hilmer, Fiscal Treatment of Managerial Compensation – a Welfare Analysis,
Progress Report, 13 August 2012.
Thomas Daske, Why Applaud when Others
Succeed? A Social Network Approach to the
Causes of Awards, 26 June 2013. Thomas Daske, Friends and Foes at Work:
Assigning Teams in a Social Network, 5 September 2012.
Rhea Molato, The Economic Cost of Secessionist Conflict in the Philippines, 9 July
2013. Michael Hilmer, Fiscal Treatment of Managerial Compensation – a Welfare Analysis,
Progress Report, 1 October 2012.
Michael Hilmer, International Corporate
Income Taxation with Tax Sparing, 17 July
2013.
Thomas Daske, Friends and Foes at Work:
Assigning Teams in a Social Network, Progress Report, 7 November 2012.
with Tax Evaders, Progress Report, 17 July
2013.
Luisa Herbst, Research Idea on Alliance
Deterrence, 18 December 2012.
Sabine Aresin, Firm Characteristics and the
CDM Decision, 20 August 2013. Anne-Kathrin Bronsert, The Nouveaux
Riches, Old Money and Conspicuous Consumption, 15 January 2013.
Rhea Molato, The Economic Cost of Secessionist Conflict in the Philippines, Progress
Report, 20 August 2013.
Luisa Herbst, Endogenous Group Formation
in Experimental Contests – Progress Report,
10 September 2013.
Michael Hilmer, Too Many to Fail – How
Bonus Taxation Prevents Gambling for Bailouts, 10 September 2013. Luisa Herbst, Balance of Power and the
Probability of War, 5 December 2013.
Sabine Aresin, Competition and the Clean
Development Mechanism, 18 December
2013.
Harald Lang, When Do Governments Repay
their Debts?, 10 September 2013. Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, Progress Report,
18 December 2013.
Philipp Meyer-Brauns, Financial Contracting with Tax Evaders, Progress Report, 10
September 2013.
Thomas Daske, Hawks and Doves Revisited – Ex Ante Optimal Labor Contracts for
Other-Regarding Agents, 14 January 2014.
Dilemma, Progress Report, 25 September
2013.
Bonus Taxation Prevents Gambling for Bailouts, 14 January 2014.
Tim Stolper, Coordination and the Fight
against Tax Havens, 14 January 2014.
Thomas Daske, Work Incentives and
Other-Regarding Preferences – The Role of
Uncertainty about a (Co-)Worker’s Type, 25
September 2013.
Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, 28 January 2014.
Rhea Molato, Public Debt and the Threat of
Secession, 25 September 2013. Luisa Herbst, Balance of Power and the
Probability of War, 28 January 2014.
Tim Stolper, The Role of Customer Coordination in the Fight Against Tax Havens, 25
September 2013.
Other-Regarding Agents, 4 February 2014.
Luisa Herbst, Pre-Investment and Bargaining
in the Shadow of Conflict, 21 October 2013.
Bonus Taxation Prevents Gambling for Bailouts, 4 February 2014.
Bonus Taxation Prevents Gambling for Bailout, Progress Report, 21 October 2013.
Against Tax Havens, 21 October 2013.
Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, 20 November
2013.
Harald Lang, Hirschman’s Tunnel Effect: Experimental Evidence, 20 November 2013.
Philipp Meyer-Brauns, Optimal Auditing
with Overconfident Taxpayers, 20 November
2013.
Rhea Molato, The Economic Cost of Secessionist Conflict in the Philippines, Progress
Report, 20 November 2013.
Sabine Aresin, Import Restrictions on Emission Credits from the CDM, 12 February
2014.
Anne-Kathrin Bronsert, Conspicuous
Consumption and Tax Evasion, 12 February
2014.
Harald Lang, Hirschman’s Tunnel Effect – Experimental Evidence, 12 February 2014.
Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, Progress Report,
27 February 2014.
Sabine Aresin, Import Restrictions on Emission Credits, Progress Report, 24 March
2014.
225
225
Strategy, Progress Report, 24 March 2014.
Harald Lang, Hirschman’s Tunnel Effect –
Experimental Evidence, Progress Report, 24
March 2014.
against Tax Havens, Progress Report, 24
March 2014.
Luisa Herbst, Bargaining with Pre-Investments: Literature, 8 April 2014.
Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, Progress Report,
22 April 2014.
Luisa Herbst, Endogenous Group Formation:
In-Group Favoritism, 22 April 2014.
Michael Hilmer, Voluntary Tax Disclosure,
22 April 2014.
Anne-Kathrin Bronsert Conspicuous Consumption and Tax Evasion, Progress-Report,
6 May 2014.
Strategy, 21 May 2014.
Tim Stolper, Heterogeneous Benefits from
Fighting Tax Havens, 21 May 2014.
Michael Hilmer, Bailout, Bonuses and Bankers’ Short-Termism, 21 May 2014.
Other-Regarding Agents, 3 June 2014.
Luisa Herbst, Endogenous Group Formation:
Revision, 24 June 2014.
June 2014.
Thomas Daske, How Other-Regarding
Agents Share Risk Efficiently, 15 July 2014.
July 2014.
226
Sabine Aresin, Optimal Import Quotas for
CERs, 19 August 2014.
Thomas Daske, Parental Upbringing and Tax
Morale, 3 September 2014.
Anne-Kathrin Bronsert, Conspicuous Consumption and Tax Evasion, 15 September
2014.
Harlad Lang, A Glance into the Tunnel – Beliefs vs. Relative-Income Considerations, 1
October 2014.
Thomas Daske, Parental Upbringing and Tax
Morale, 24 November 2014.
Luisa Herbst, Balance of Power: Additional
Treatments, 24 November 2014.
Harald Lang, A Glance into the Tunnel –
Beliefs vs. Relative-Income Considerations
– New Sessions –, 11 December 2014.
II Participation at Conferences,
Congresses, and Conventions
Celebration of the 20th Anniversary of EC Tax
Review-Fiscal Sovereignty, European Association of Tax Law Professors, Rotterdam,
Netherlands, May 2012 (Konrad).
2012
Munich Economic Summit 2012, BMW
Stiftung Herbert Quandt, Munich, May 2012
(Dwenger, Konrad).
Die Zukunft der Energieversorgung:
Atomaustieg, Versorgungssicherheit und
Klimawandel, Bayerische Akademie der
Wissenschaften, Munich, January 2012
(Aresin).
Verfassungsrechtliche Probleme der
Euro-Rettung, Prof. Dr. Dietrich Murswiek,
Munich Seminars, CESifo Group, Munich,
January 2012 (Konrad).
V. Tax Day, MPI for Tax Law and Public
Finance, Munich, January 2012 (Bronsert,
Dwenger, Elsayyad, Grijalva, Herbst, Hilmer, Ke, Konrad, Meyer-Brauns, Qari, Tan).
Science Research Center Berlin (WZB), Berlin, February 2012 (Konrad).
Financial Crisis in Europe, Norwegian School
of Economics (NHH) and E.ON Ruhrgas
Scholarship Program, Bergen, Norway,
March 2012 (Konrad).
Finance, MPI for Tax Law and Public Finance, Munich, March 2012 (Aresin, Bronsert, Daske, Dwenger, Elsayyad, Herbst,
Hilmer, Ke, Molato).
Die Roller der Kernfusion im Energiemix der
Zukunft, Prof. Dr. Sibylle Günter, Munich
Seminars, CESifo Group, Munich, April 2012
(Aresin).
ESP 2012, CESifo Area Conference 2012,
CESifo Group, Munich, April 2012 (Hilmer).
Finance, Schliersee, May 2012 (Aresin,
Bronsert, Daske, Dwenger, Elsayyad,
Herbst, Hilmer, Ke, Konrad, Qari, Tan).
2012 Henry A. Kissinger Prize, Honoring
George P. Shultz, The American Academy in
Berlin, Berlin, May 2012 (Konrad).
Steuergesetzgebung und Steuersystematik,
Symposium zu Ehren von Herrn Ministerialdirigenten Eckehard Schmidt, MPI for Tax
Law and Public Finance, Munich, May 2012
(Konrad).
Tax Competition among U.S. States: Racing
to the Bottom or Riding on a Seesaw? Bob
Chirinko (University of Illinios at Chicago),
May 2012 (Konrad).
VI. Tax Day, MPI for Tax Law and Public Finance, Munich, January 2012 (Aresin, Bronsert, Dwenger, Frey, Grijalva, Ke, Konrad,
Meyer-Brauns, Molato, Tan).
Science Research Center Berlin (WZB), Berlin, June 2012 (Konrad).
Basel III und ESRB – kann so mehr Finanzmarktstabilität erreicht werden?, ECONWATCH, Berlin, June 2012 (Konrad).
Verleihung der Würde eines Ehrensenators
im Europäischen Wirtschaftsforum e. V.
(EwiF) an Prof. Dr. Dres. h.c. Paul Kirchhof,
Union Mittelständischer Unternehmen
(UMU), Munich, June 2012 (Konrad).
Workshop on Taxation and Redistribution,
June 2012 (Aresin, Bronsert, Daske, Elsayyad, Herbst, Hilmer, Ke, Konrad, Molato,
Qari, Tan).
Workshop Natural Experiments and Controlled Field Studies, Holzhausen am Ammersee, June 2012 (Aresin).
Creating Moral Wiggle Room: Strategies to
Avoid Accountability for Unfair Behaviour,
Prof. Björn Bartling, CES Lectures, CESifo
Group, Munich, July 2012 (Tan).
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227
Intangibles and Transfer Pricing, Interdisciplinary Conference, MPI for Tax Law and
Public Finance, Munich, July 2012 (Daske).
Topics in the Design and Analysis of Experiments, Prof. Daniel Houser, CES Lectures,
CESifo Group, Munich, July 2012 (Tan).
Public Finances and the New Economic Governance, 2nd Public Finance Dialogue, Hertie
School of Governance/Federal Ministry of
Finance, Berlin, August 2012 (Konrad).
Conferment of the M100 Sanssouci Media
Award to Mario Draghi, What Kind of Europe? Learning from the Crisis, Potsdam,
September 2012 (Konrad).
Munich-Tokyo-Conference on Federal Public
Finance, Munich, September 2012 (Aresin,
Bronsert, Daske, Herbst, Hilmer, MeyerBrauns, Molato).
VII. Tax Day, MPI for Tax Law and Public Finance, Munich, September 2012 (Bronsert,
Daske, Elsayyad, Herbst, Hilmer, Konrad,
Meyer-Brauns, Molato, Tan).
Economics, Munich, October 2012 (Aresin,
Bronsert, Daske, Elsayyad, Herbst, Hilmer,
Konrad, Lang, Morath, Stolper).
Modekrankheit: Verdrossenheit, Hauptstadtsalon, Berlin, October 2012 (Konrad).
11. Finanzwissenschaftliches Seminar, Social
Science Research Center Berlin (WZB), Berlin, November 2012 (Konrad).
Conference on The End of Federalism?, Social Science Research Center Berlin (WZB),
Berlin, October 2012 (Konrad, Molato,
Qari).
Abschieds- und Antrittsvorlesung Klaus-Dirk
Henke und Prof. Dr. Marco Runkel, Technische Universität Berlin, Berlin, November
2012 (Konrad).
Gender Equality and Development, Prof. Esther Duflo, Munich Lectures in Economics, CESifo Group, Munich, November 2012
(Konrad, Lang, Stolper).
228
MPG-CASS Conference on Perspectives of
Cooperation, Administrative Headquarters
of the Max Planck Society, Munich, November 2012 (Konrad).
Arbeitsmarktpolitik für Deutschland – 15
Jahre IZA, Jubilee, Institute for the Study of
Labor (IZA), Berlin, December 2012 (Konrad).
Der Euro: Probleme und Lösungsmöglichkeiten, Prof. Dr. Stefan Homburg, Munich
Seminars, CESifo Group, Munich, December
2012 (Aresin).
Staatsschulden in der Demokratie: Ursachen, Wirkungen und Grenzen, German
National Academy of Science (Leopoldina)
and Freie Universität Berlin, Berlin, December 2012 (Konrad).
Wie viel Vertrauen verdient der Euro? Prof.
Dr. Manfred J.M. Neumann, Munich Seminars, CESifo Group, Munich, December 2012
(Aresin).
2013
Wohlstand für alle? Langfristige Wirtschaftsentwicklung aus globaler Sicht, Prof. Dr.
Uwe Sunde, Inaugural Lecture, LudwigMaximilians-Universität München, Munich,
January 2013 (Konrad).
Centre for Business Taxation, Saïd Business
School, Oxford, UK, March 2013 (Bronsert,
Hilmer, Konrad, Meyer-Brauns, Morath,
Stolper).
CESifo Area Conference on Public Sector
Economics, CESifo, Munich, April 2013
(Lang).
Workshop on Contests: Experiments and
Theory, MPI for Tax Law and Public Finance,
Munich, January 2013 (Aresin, Bronsert,
Daske, Dwenger, Elsayyad, Herbst,
Hilmer, Konrad, Lang, Meyer-Brauns, Qari,
Stolper).
Corporate Taxation – the Next Building
Block of a Future Fiscal Union?, Centre for
European Economic Research (ZEW), Mannheim, Representation of the State of BadenWürttemberg to the European Union, Brussels, Belgium, April 2013 (Hilmer).
Workshop on Public Economics and Public
Policy, University of Copenhagen, Copenhagen, Denmark, January (Dwenger).
Economics III, MPI for Tax Law and Public
Finance and MPI of Economics, Jena, April
2013 (Herbst).
50 Jahre Sachverständigenrat (1963-2013),
The German Council of Scientific Experts,
Berlin, February 2013 (Konrad).
Ceremonial Act at the Occasion of the
Handover of the Presidential Office, Centre
for European Economic Research (ZEW),
Mannheim, February 2013 (Konrad).
Steuerpolitik im Umfeld neuer Fiskalinstitutionen und Abstimmungsverfahren,
PAKT Project, Mannheim, February 2013
(Dwenger).
CESifo Area Conference on Macro, Money
and International Finance, CESifo, Munich,
February 2013 (Konrad, Lang).
V. Munich Economic Summit Lecture: Alternativen zur Transferunion, Ifo und BMW
Stiftung, Hotel Bayerischer Hof, Munich,
March 2013 (Aresin, Hilmer, Lang).
Finance, Munich, March 2013 (Aresin,
Bronsert, Dwenger, Elsayyad, Herbst, Konrad, Lang, Molato, Stolper).
Innsbruck-Munich Conference on Public
Finance, University of Innsbruck, Austria,
Innsbruck, March 2013 (Konrad).
Allocation of the Tax Base, MPI for Tax
Law and Public Finance, Oxford University
Richard Musgrave Lecture by Joel B. Slemrod, Munich, April 2013 (Hilmer, Lang,
Stolper).
Tax Compliance, International Fiscal Association (IFA), Munich Re, Munich, April 2013
(Hilmer).
CESifo Area Conference on Employment and
Social Protection, CESifo Group, Munich,
May 2013 (Bronsert, Dwenger, Konrad).
Öffentliche Finanzen und Politische Ökonomie I, MPI for Tax Law and Public Finance,
Joint Seminar with Bruno Frey, Schliersee,
May 2013 (Aresin, Bronsert, Herbst, Lang,
Molato, Stolper).
Base Erosion and Profit Shifting – Welche Instrumente werden benötigt?, International
Fiscal Association (IFA), Deloitte & Touche,
Munich, June 2013 (Hilmer, Stolper).
Die Europäische Schuldenkrise – die Rolle
von Freiheit und Verantwortung, Lecture
Prof. Kai A. Konrad, Munich Seminars, CESifo
Group and Süddeutsche Zeitung, Munich,
June 2013 (Bronsert, Hilmer, Stolper).
Münchner Volkswirte Alumni Club e.V.
Jahresfestveranstaltung, Munich, June 2013
(Lang).
Workshop Natural Experiments and
Controlled Field Studies, Holzhausen am
229
229
Ammersee, June 2013 (Aresin, Dwenger,
Herbst).
Public Finance, Munich, November 2013
(Bronsert, Dwenger).
Barcelona Banking Summer School, Barcelona Graduate School of Economics, Barcelona, Spain, July 2013 (Lang).
X. Tax Day, MPI for Tax Law and Public Finance, Munich, November 2013 (Bronsert,
Daske, Dwenger, Herbst, Hilmer, Konrad,
Lang, Meyer-Brauns, Molato, Morath, Qari,
Stolper).
Finanzwissenschaftliches Forschungsseminar, Ifo Institute, Munich, July 2013 (Hilmer,
Lang).
National Bureau of Economic Research
(NBER) Summer Institute, Cambridge, USA,
July 2013 (Dwenger).
Rechnen mit dem Scheitern: Individuelle
und kollektive Strategien in ungewissen
Zeiten, Convoco Forum 2013, Salzburg, Austria, July 2013 (Konrad).
IX. Tax Day, MPI for Tax Law and Public
Finance, Munich, August 2013 (Aresin,
Bronsert, Daske, Dwenger, Herbst, Hilmer,
Konrad, Lang, Meyer-Brauns, Molato, Morath, Qari, Stolper).
Reading Workshop “Successful Candidates
on the US Job Market”, Ludwig-MaximiliansUniversität München, Munich, August 2013
(Stolper).
Finance, Kreuth, September 2013 (Bronsert,
Daske, Herbst, Konrad, Molato, Tan).
Public Finance, Munich, September 2013
(Aresin, Bronsert, Daske, Dwenger, Herbst,
Hilmer, Lang, Meyer-Brauns, Molato, Morath, Stolper, Tan).
Advances on the Political Economy of
Conflict and Redistribution II, Social Science
Research Center Berlin (WZB), Berlin, October 2013 (Herbst, Konrad, Morath, Tan).
CESifo Area Conference on Behavioural
Economics 2013, CESifo, Munich, October
2013 (Lang).
8th Young Researchers Workshop, SFB/TR 15,
Munich, November 2013 (Herbst).
Conference on Tax Law, MPI for Tax Law and
230
17th Conference of the SFB/TR 15 Governance and the Efficiency of Economic Systems, Tutzing, November 2013 (Herbst).
Celebration of the 32th Munich Lectures,
CESifo Group, Munich, November 2013
(Konrad).
Evaluation ZEW-Unternehmensbesteuerung,
(ZEW), Mannheim, November 2013 (Konrad).
Finance, Munich, November 2013 (Bronsert,
Daske, Gerritsen, Herbst, Hilmer, Hornung,
Konrad, Meyer-Brauns, Molato, Morath,
Qari, Stolper, Tan).
Norwegian-German Seminar on Public Economics, CESifo and the Norwegian Center
for Taxation, Munich, November 2013 (Gerritsen).
Taxing Multinational Firms, Centre for European Economic Research (ZEW), University
of Mannheim and Oxford University Centre
for Business Taxation, Mannheim, November 2013 (Dwenger, Hilmer, Hornung,
Stolper).
The Long Shadow of History – Mechanisms
of Persistence in Economics and the Social
Sciences, Centre for Business Taxation,
Mannheim, November 2013 (Hornung).
Third CREA Conference Talk on Economics –
Monetary Policy and Global Capital Markets
– New Perspectives, New Opportunities,
New Dangers, University of Luxembourg,
Luxembourg, November 2013 (Lang).
12. Finanzwissenschaftlicher Workshop,
Social Science Research Center Berlin (WZB),
Berlin, December 2013 (Konrad).
2014
und Feld”, Ifo Institute, Munich, April 2014
(Aresin).
Conference on Base Erosion and Profit Shifting: A Roadmap for Reform, International
Network for Tax Research and MPI for Tax
Law and Public Finance, Munich, January
2014 (Konrad).
18th Conference of the SFB/TR 15, Governance and the Efficiency of Economic
Systems, Centre for European Economic
Research (ZEW), Universität Mannheim,
Mann-heim, April 2014 (Herbst).
Workshop on Understanding Tax Havens,
MPI for Tax Law and Public Finance and
Norwegian School of Economics, Munich,
January 2014 (Aresin, Bronsert, Daske,
Dwenger, Elsayyad, Gerritsen, Herbst, Hilmer, Hornung, Konrad, Lang, Meyer-Brauns,
Molato, Morath).
CESifo Area Conference on Public Sector
Economics, CESifo Group, Munich, April
2014 (Bronsert, Stolper).
Streitgespräch zur Zukunft der Eurozone,
Freie Universität Berlin, Berlin, January 2014
(Konrad).
Vom Übeltäter zum Umweltretter: Mit sozialer Martkwirtschaft allein ist die Umwelt
nicht zu retten, Dr. Anselm Görres, Munich
Seminars, CESifo Group, Munich, April 2014
(Aresin).
CESifo Spanish-German Economic Dialogue,
CESifo Group, Munich, February 2014
(Lang).
Sitzung der Bundesarbeitsgruppe Staatsfinanzen, Wirtschaftsrat der CDU e.V., Berlin,
February 2014 (Konrad).
Wirtschaftspolitik in Deutschland: Spielen
Parteien eine Rolle? Prof. Dr. Nikals Potrafke,
Inaugural Lecture, Ludwig-MaximiliansUniversität München, Munich, February
2014 (Konrad).
Working on Insoluble Problems, Prof. Bazon
Brock, Convocos 10th Anniversary, Convoco
Foundation, Berlin, February 2014 (Konrad).
Berlin Behavioral Economics Workshop,
Berlin, March 2014 (Konrad).
Conference on Das Reichswirtschaftsministerium im Nationalsozialismus, Federal
Ministry for Economic Affairs and Energy,
Berlin, March 2014 (Konrad).
XI. Tax Day, MPI for Tax Law and Public
Finance, Munich, March 2014 (Aresin,
Bronsert, Daske, Gerritsen, Herbst, Hilmer,
Hornung, Meyer-Brauns, Molato, Morath,
Stolper).
Richard Musgrave Lecture by Prof. James
R. Himes, Jr., CESifo, Munich, April 2014
(Stolper).
4th SEEK Conference on Public Finance and
Income Distribution in Europe, Center for
the European Economic Research (ZEW),
Mannheim, May 2014 (Konrad).
CESifo Area Conference on Employment and
Social Protection, CESifo Group, Munich,
May 2014 (Konrad).
Die Europäische Fiskal- und Bankenunion,
Clemens Fuest, Munich Seminars, CESifo
Group, Munich, May 2014 (Lang).
Lecture about the European Debt Crisis,
Jeromin Zettelmeyer, Ludwig-MaximiliansUniversität München, Munich, May 2014
(Konrad, Hilmer).
PAKT-Workshop – Pakt für Forschung und
Innovation, Centre for European Economic
Research (ZEW), Mannheim, May 2014
(Stolper).
The Internet as a Tax Haven? The Effect of
the Internet on Tax Competition, Public
Finance and Economic Policy – Special
Seminar, Ludwig-Maximilians-Universität
München, Munich, May 2014 (Gerritsen,
Hilmer).
2. Energiepolitischer Workshop “Bioenergie
– Wie viel Energiewende wächst auf Baum
231
231
Workshop on Political Consulting in Germany: A Profile, Otto-von-Guericke-University
Magdeburg, Magdeburg, May 2014 (Konrad).
28th Annual Conference of the European
Society for Population Economics, Braga,
Portugal, June 2014 (Bronsert).
Ein Blick auf die Wettbewerbspolitik von
morgen – in Deutschland, Europa und
weltweit, Andreas Mundt, MPI for Innovation and Competition, Munich, June 2014
(Hilmer).
VAC Jahresfestveranstaltung 2014, Münchner Volkswirte Alumni Club e.V., Munich,
June 2014 (Lang).
Workshop on Natural Experiments and
Controled Field Studies, sponsored by the
Fritz-Thyssen Stiftung, the SFB/TR-15, and
the Economics Departments of the Universities of Munich and Ulm, Ohlstadt, June 2014
(Aresin).
Workshop on Öffentliche Finanzen und
Frey and Marcel Thum, Munich, 17-18 June
2014 (Aresin, Daske, Gerritsen, Hilmer, Hornung, Konrad, Lang, Meyer-Brauns, Molato,
Morath, Stolper).
Workshop on Policy Challenges for the Euro
Area, Villa Vigoni, Loveno di Menaggio,
Como, Italy, June 2014 (Konrad).
37th Annual NBER Summer Institute, Economic Fluctuations and Growth, Cambridge,
USA, July 2014 (Hornung).
Academia Europaea 26th Annual Conference, Institut d’Estudis Catalans, Barcelona,
July 2014 (Konrad).
Einführung zum Thema “Hyperbolisches
Diskontieren”, “Du sollst nicht... – das Unterlassen als die höchste Form des Handelns”,
Convoco Foundation, Salzburg, Austria, July
2014 (Konrad).
Finanzwissenschaftliches Forschungsseminar, Ifo Institute, Munich, July 2014 (Hilmer,
Lang).
232
Was ist Führung? / Innovationen – Neue
Forschungsansätze, Innaugural Lecture,
Prof. Dr. Martin Högl and Prof. Dr. Dietmar
Harhoff, Ludwig-Maximilians-Universität
München, Munich, July 2014 (Konrad).
XII. Tax Day, MPI for Tax Law and Public Finance, Munich, July 2014 (Aresin, Bronsert,
Daske, Dwenger, Gerritsen, Herbst, Hilmer,
Konrad, Lang, Meyer-Brauns, Molato, Morath, Stolper, Tan).
3. Energiepolitischer Workshop “Bioenergie
– Wie viel Energiewende wächst auf Baum
und Feld”, Ifo Institute, Munich, September
2014 (Aresin).
5th Meeting in Economic Sciences, Lindau
Nobel Laureates Meeting, Lindau, August
2014 (Hornung).
IIPF Doctoral School on International Corporate Taxation, Oxford University Centre for
Business Taxation, Oxford, UK, September
2014 (Stolper).
Workshop on Contest Theory and Political
Competition, MPI for Tax Law and Public
Finance, Munich, September 2014 (Brückerhoff, Gerritsen, Hornung, Konrad, Lang,
Morath).
Annual Meeting of the SFB/TR 15, Governance and the Efficiency of Economic Systems, Caputh, October 2014 (Morath).
CESifo Area Conference on Behavioural
Economics 2014, CESifo, Munich, October
2014 (Lang).
Copenhagen Workshop on Attention in Economics, Universtiy of Copenhagen, Copenhagen, Denmark, October 2014 (Stolper).
2nd Joint Experimental Workshop, University
of Innsbruck, Innsbruck, Austria, October
2014 (Dwenger, Gerritsen, Konrad, Lang,
Morath, Simon).
Jour Fixe, Munich Experimental Laboratory
for Economic and Social Sciences MELESSA,
Munich, October 2014 (Lang).
Joint Conference on The Comprehensive Assessment, the ECB’s New Role and Limits of
a Common Supervision in the EU, Brussels
Think Tank Bruegel, German Institute for
Economic Research (DIW), ESMT European
School of Management and Technology and
the Jacques Delors Institute, Berlin, October
2014 (Brückerhoff, Konrad).
MGSE Welcome Day, Munich Graduate
School of Economics (MGSE), LudwigMaximilians-Universität München, Munich,
October 2014 (Konrad).
Rethinking the Global Currency System, Prof.
Kenneth S. Rogoff, Munich Lectures in Economics, CESifo Group, Munich, November
2014 (Konrad, Lang).
The Long Shadow of History – Mechanisms
of Persistence in Economics and the Social
Sciences, Center for Advanced Studies and
Munich, November 2014 (Hornung).
XIII. Tax Day, MPI for Tax Law and Public
Finance, Munich, November 2014 (Aresin,
Brückerhoff, Daske, Herbst, Konrad, Lang,
Morath, Simon).
13. Finanzwissenschaftlicher Workshop,
Berlin, December 2014 (Konrad).
Lecture by Joel Slemrod, University of Copenhagen, Copenhagen, Denmark, December 2014 (Stolper).
The Law and Economics of Sovereign Debt
and Default, Mitu Gulati and Lee C. Buchheit, CES Lecture, CESifo Group, Munich,
December 2014 (Simon).
IIIParticipation on Committees
Nadja Dwenger
Arbeitskreis Finanzwissenschaft, Federal
Ministry of Finance, Berlin, March 2013.
Arbeitskreis Finanzwissenschaft, Federal
Ministry of Finance, Berlin, March 2014.
Erik Hornung
Tax Law and Public Finance, July 2014.
Kai A. Konrad
Meeting of the Council of Scientific Advisors
to the Federal Ministry of Finance, Berlin,
January 2012.
Meeting of the Humanities Section and the
Advisory Board of the Max Planck Society,
Meeting of the ZEW Scientific Committee,
(ZEW), Mannheim, February 2012.
March 2012.
Second Meeting MPI of Economics, Administrative Headquarters of the Max Planck
Society, Munich, March 2012.
to the Federal Ministry of Finance, Leipzig,
May 2012.
Annual Conference, Meeting and Symposium of the Humanities Section of the Max
Planck Society, Düsseldorf, June 2012.
to the Federal Ministry of Finance, Cologne,
June 2012.
Meeting of the ZEW Scientific Committee,
(ZEW), Mannheim, June 2012.
233
233
September 2012.
Meeting of the Humanities Section of the
Max Planck Society, Berlin, October 2012.
Sozialpolitischer Ausschuss, Social Science
Research Center Berlin (WZB), Berlin, October 2012.
CES Council Meeting, Center for Economic
Studies (CES), Munich, November 2012.
November 2012.
Meeting of the Perspectives Commission of
the Max Planck Society, Berlin, December
2012.
Meeting of the Scientific Advisory Board of
the RWI, Essen, November 2012.
January 2013.
Meeting of the Board of Trustees of ECONWATCH, Berlin, February 2013.
Meeting of the ZEW Scientific Council, Centre for European Economic Research (ZEW),
Mannheim, February 2013.
March 2013.
to the Federal Ministry of Finance, Weimar,
April 2013.
the Max Planck Society, Munich, April 2013.
E.ON Ruhrgas Scholarship Program, Mannheim, April 2013.
Annual Conference and Meeting of the Humanities Section of the Max Planck Society,
Potsdam, June 2013.
234
Statement by Germany’s Constitutional
Court on the ECB’s OMT Programme, Federal Constitutional Court, Karlsruhe, June
2013.
to the Federal Ministry of Finance, Mainz,
July 2013.
Working Group of the Technische Universität Dresden, Tenure Track, Frankfurt, July
2013.
September 2013.
the Max Planck Society, Bonn, September
2013.
Meeting of the Humanities Section of the
Max Planck Society, Berlin, October 2013.
Working Group of the Technische Universität Dresden, Tenure Track, Frankfurt,
October 2013.
Working Group of the Technische Universität Dresden, Tenure Track, Frankfurt,
November 2013.
November 2013.
the Max Planck Society, Bonn, December
2013.
Meeting of the Scientific Advisory Board
of the Rheinisch-Westfälisches Institut für
Wirtschaftsforschung (RWI), Essen, December 2013.
Working Group, National Academy of Science and Engineering (acatech), Berlin,
December 2013.
January 2014.
Meeting of the ZEW Scientific Council,
Center for the European Economic Research
(ZEW), Mannheim, February 2014.
March 2014.
E.ON Ruhrgas Meeting, E.ON, Dresden, April
2014.
to the Federal Ministry of Finance, Münster,
May 2014.
Wirtschaftsforschung (RWI), Essen, November 2014.
CES Council Meeting & Area Directors
Meeting, Center for Economic Studies (CES),
Working Group, National Academy of Science and Engineering (acatech), Berlin,
December 2014.
Harald Lang
“Report on Shadow Prices”, Advisory Assignment, European Investment Bank (EIB),
Luxembourg 2013.
PAKT, Center for the European Economic
Research (ZEW), Mannheim, May 2014.
2014.
Annual Conference and Meeting of the Humanities Section of the Max Planck Society,
Munich, June 2014.
“Report on Shadow Prices”, Advisory Assignment, European Investment Bank (EIB),
Luxembourg, 2014.
to the Federal Ministry of Finance, Hamburg, July 2014.
the Max Planck Society, Berlin, September
2014.
E.ON Scholarship Program, Berlin, September 2014.
September 2014.
Salmai Qari
Deputy Head, Search Committee for a
Professorship in Statistics, Hochschule für
Wirtschaft und Recht Berlin, Berlin, July
2014.
Fanfang Tan
Postdoctoral (Senior Research Fellow) Job
Search Committee, MPI for Tax Law and
Public Finance, Munich, January 2012.
SAB Meeting, Kiel Institute for the World
Economy, Kiel, November 2014.
November 2014.
Symposium of German National Academy of
Science Leopoldina, Halle/Saale, November
2014.
Meeting of the Scientific Advisory Board
of the Rheinisch-Westfälisches Institut für
235
235
Services
(left to right and front to back): Hendrik Wanger, Sabrina
Wittmann, Donika Doqi, Kerstin Gabler, Gabriele Zinczuk,
Elfriede Stangl, Cornelia Zimmermann.
236 Services
Administration
Focal Points and Challenges in the
Years 2012–2014
The Administration looks after all administrative matters for the Max Planck
as well as for its sister, the Max Planck
Institute for Innovation and Competition. In this regard the administrative
work is shouldered by three main units,
human resources, finance (financials,
funds management) and general administration (including procurement and real
estate).
For the Administration, the years 2012
and 2013 were predominantly marked
by the expansion of the sister Institute by
a third department that focuses on economics. This was implemented with the
appointment of Prof. Dietmar Harhoff,
Ph.D. on 1 January 2013.
To start with, space had to be found for
around 40 extra people, including the
junior academic staff. Following negotiations with the General Administration of
the Max Planck Society, a section of the
third floor in the building in Marstallplatz
was made available to accommodate the
new Department. Additional space was
leased at Karl-Scharnagl-Ring 7 for the
Administration, the IT-Department and a
newly established experimental laboratory used jointly by Prof. Dr. Kai A. Konrad
and Prof. Dietmar Harhoff, Ph.D. for both
Institutes. The relocation of the service
departments took place in autumn 2013.
Both Institutes, originating from the for-
mer MPI for Intellectual Property, Competition and Tax Law, are now spread
over three locations including the service
facilities (Marstallplatz 1, Marstallstrasse
8 and Karl-Scharnagl-Ring 7). The Administration’s employees met the additional
workload with a surge in energy and
commitment and took additional charge
of, for example, countless procurement
measures for equipment, coordination
of the renovation works for the rooms
and floors, the transfer of staff and new
employees, as well as the increase in real
estate. Due to the separation of work
areas, some work processes had to be
re-organised.
The new Department was finally fully
integrated within the sister Institute on
its renaming from “Intellectual Property
and Competition” to “Innovation and
Competition” at the turn of the year
2013/2014.
The Supreme Bavarian Audit Court
performed an audit of both Institutes’
activities in 2013 and 2014. The audit
examined the use of funds allocated by
the Federal Government and the States
and focussed on compliance with statutory provisions, workplace agreements
and budgetary rules. The final report was
provided to both Institutes in December
2014; it led to a successful finalisation.
Moreover, a workplace agreement for
the distribution of bonus payments under the LoB principles (LoB stands for
Administration
237
performance-oriented payment) was
signed.
Furthermore, in the reporting period
there were numerous changes to statutory and workplace agreement laws. In
February 2014, with retrospective effect
from 1 January 2014, the new schedule
for payment grades in German public services entered into force. Given changed
job descriptions and job specifications
in the public service, the law regarding payment grades, which was in part
very out of date, was comprehensively
modernised. The old BAT (Bundes-Angestelltentarifvertrag – Federal Employee
Workplace Agreement) job characteristics applied until 31 December. While retaining the payment grade used to date,
the employees at the Institute were successfully transitioned to the TVÖD Bund
(Tarifvertrag für den Öffentlichen Dienst
– German Federal Workplace Agreement
for the Public Service). Payment grade
9 was replaced by payment grades 9a
and 9b. The correct allocation for the affected employees had to be individually
identified in each case.
The accounting system within the Max
Planck Society was further developed
238 Services
in accordance with the requirements of
the fondus and the GWK (gemeinsame
Wissenschaftskonferenz – Joint Academic Conference) and also left its mark
in the Institute’s accounting. The goal is
to establish an accounting system that
meets all the requirements of a research
institute and to prepare an annual report
(preceded by annual financial statements) in accordance with commercial
law principles, which can then be audited
by external auditors (to date, by internal
revision). There will now be an earnings
and costs-based budget as opposed to a
simple statement of cash and expenses. A
further focal point within the accounting
system was the Europe-wide conversion
to IBAN and BIC for payments (core creditor data). As part of the new accounting
system, the capital list of assets and the
inventory were also given a new format.
In accordance with the new inventory
directive for the capital assets of the Max
Planck Society, in the period from the
end of March to the end of June 2014,
a huge stocktake was carried out at the
Institute. In October 2014 the due and
proper implementation of the new specifications was examined and confirmed by
the revision.
Head of Administration
 Hendrik Wanger (from 01.07.2013)
 Bernd Höller (until 31.07.2013)
Ulrike Mayer – Assistant to the Head of Administration
Trainees
 Donika Doqi (Management Assistant for Office Communication),
Sinja Koestler (from 01.09.2014 Office Management Assistant)
Financials
 Kerstin Gabler, Elfriede Hurmer, Monika Reeck (until 31.12.2014),
Cornelia Zimmermann
Human Resources
 Petra Schwarz, Elfriede Stangl, Christl Werner (from 01.03.2013),
Martina Wette (until 08.08.2012)
Facility Management
 Jakica and Zdenko Caganic, Zoltan Pavkovics (from 01.05.2014),
Manfred Schwarz
Travel Agent
 Gabriele Zinczuk
Housing, Cashier’s Office

Stilla Wenger
Central Purchasing
 Sabrina Wittmann
Administration
239
IT Services
As a part of the common services division for the Max Planck Institute for Innovation and Competition and the Max
Finance, the IT Department delivers
central services for data processing and
communication for both Institutes. The first half of 2012 was characterised
by the work required to conclude the
migration to Windows 7 and Office 2010.
Institute employees received trainings
in the new software; the IT Department
created documents for private study and
training videos for this purpose. In addition, in 2012 the ESX server farm under
VM-Ware was updated to version 5.
The storage sub-system was expanded
through the strong growth in the amount
of data in the academic divisions. Due
to the advanced age of the system the
expansion could only be achieved by
means of refurbished discs (and thus also
cost-effectively).
The years 2013 and 2014 deserve particular attention in the reporting period.
The IT Department was particularly challenged by the relocation of Administration
and IT to the new site at Hofgarten-Palais
on Karl-Scharnagl-Ring, the appointment
of Prof. Dietmar Harhoff, Ph.D. and the
associated creation of a new department
at the MPI for Innovation and Competition, and the establishment of the Max
Planck Laboratory for Experimental Research and Social Sciences econlab.
240 Services
IT Infrastructure for a new economicsorientied research department at the sister institute The planning and establishment of the IT infrastructure for the new
Department at the Max Planck Institute
for Innovation and Competition began in
2013. Since the new Department covers
an entire floor at the site at Marstallplatz
1, the existing IT infrastructure had to be
expanded substantially.
Relocation of the Administration
and the IT Department
In September 2013, the Administration
and IT Department relocated to the new
building at Karl-Scharnagl-Ring 7, and
this was preceded by comprehensive
planning regarding the necessary IT infrastructure. Among other work, a new
server room was established for the
laboratory server, the switching components and the new backup system.
Max Planck Laboratory for Experimental Research for Social Sciences
(econlab)
In 2013 and 2014 the planning and establishment of the IT infrastructure for the
“Max Planck Laboratory for Experimental Research for Social Sciences” (econlab) took place. With consideration given
to the specific requirements of economic
scientists, six work places for laboratory
staff and 24 laboratory places were established; in addition a server farm with
a “Citrix-Zen” server was installed for
the experiments. For the planning of the
experiments “Orsee” software was implemented as an administrative tool and
it was adapted to the requirements of
the laboratory and a programme for the
remote control of the laboratory places
was developed. Furthermore, an Internet site for the laboratory was created
(www.econlab.mpg.de).
Expansion of the IT Infrastructure
At the end of 2012, at the request of the
library, a new solution for the payment
of deposits for the guest print and copy
cards was developed and implemented.
In addition, in the second half of 2013 a
new VPN (Virtual Private Network) solution was implemented in order to meet
the increased requirements of academics for external access to the IT systems.
In December 2013, at the request of the
New building at Karl-Scharnagl-Ring 7,
for the Administration, the IT Department and a newly established experimental laboratory.
academic departments and with the help
of new software (“Viewfinity”), access
to the personal PCs with administrative
rights was made possible. In addition the
“Nexthink” software was acquired, with
the help of which an end user IT analysis
makes it possible to significantly reduce
the time required for troubleshooting
and increase the user-friendliness of the
Help Desk. Following extensive testing
and with the involvement of the employee organisation and the end-users
the software was released in the fourth
quarter of 2014 for the system administration. Since Summer 2014 the W-LAN
network “EduRoam” has also been available to both Institutes.
IT Services
241
CMS and Workflow for Scholarship
Students
In November 2013, work began on the
conversion of the Content Management
System (CMS) used to date, “Contens”,
to the new open source CMS “Typo3”.
The conversion work will be completed
in February 2015. In anticipation of the
conversion to the new CMS, the programming of a new scholarships-workflow
began in 2014 and this was successfully
completed in December 2014.
Head of IT
 Klaus Herfurtner
Staff
 Alfred Kaiser (since August 2013), Heiner Leitl, Jens Leber, Hans Müller, Christopher Rowland (until May 2014), Michael Wildgruber (until May 2013), Kfir Arbel (since July 2013)
Trainees
 Thomas Grillenberger (since September 2012), Markus Hackbarth (until July 2014), Dominik Huber (since September 2014), Victor Tietze (since September 2013), Patrick Gabler (until July 2013)
242 Services
PRess AnD meDiA ReLAtions
Thepressandmediarelationsunitisresponsibleforkeepingthepublicupdated
with reports on the Institute’s work.
ThepositioniscurrentlyheldbyChrista
Manta on a part-time basis. She is responsiblefortheInstitute’swebsite,for
the Institute’s publications, such as the
interim and the activity reports, for the
conception and distribution of informationmaterialliketheInstitute’sflyer,and
for the dissemination of scientific information via the electronic journal “Max
Finance Research Paper Series” on the
SocialScienceResearchNetworkSSRN.
Christa Manta
news and the Institute’s recent publications.Itsdevelopmentanddistributionis
inthehandsofthepublicrelationsunit
–fromtheconceptandtheeditingtothe
graphicaldesignandthetype-setti
ng.
press Relations
Thedirectorsinparticulararefrequently
requested as dialogue partners by the
media.Theygiveinterviewsandprovide
exclusivereportsandarticlesfornational
andinternationalpress.Theissueswhich
receivedmostattentioninthereporting
period were the European economic
and financial crisis, the problem of tax
havens, of the tax avoidance strategies
multinational firms apply and the allocation of taxing rights in international
context.From2012to2014,theInstitute
anditsscientificstaffwasquotedintotal
byaround400regional,nationalandinternationalprintandonlinepublications,
TV and radio.
Newsletter
OneofthemajorinnovationsinthereportingperiodwasthelaunchofanewsletterinJuly2013.Thenewlydeveloped
newsletterisavailableinprintandonline
andisdesignedtoaddressboththescientificandnon-scientificgeneralpublic.
ItreportstwiceayearinEnglishonnew
research projects and results, selected
lectures and conferences, on personnel
newsletter
Private l aw as a develoPment aid........................................6
alliances and solidarit y.........................................................7
TA Xing cross-border services................................................8
crisis MeAsures before The consTiTuTionAl courT.........9
selec Ted PublicATions.............................................................13
M a x P l a n c k I n s t I t u t e f o r ta x l aw a n d P u b l I c f I n a n c e
i s s u e 01/2013
press and Media Relations
243
(left to right): Ina Wockenfuss, Caterina Maul, Ludwig Rickert, Elke List, Annika Dolabdjian,
Claudia Metz, Sabine Schmotz, Marcus Noack, Peter Weber (Library Director), Carmen Diana
Holzer, Roswitha Schmidt (not shown: Petra Golombek, Christin Lindemann).
244 Services
Library
The library, under the direction of Peter
Weber, consolidated its comprehensive
range of services in the reporting period
and was able to expand in certain key areas. Since 2011 the library, and its employees, have served as a central service unit
for the provision of academic information
not only for the Max Planck Institute for
Tax Law and Public Finance but also to the
same extent for the Max Planck Institute
for Innovation and Competition.
1. Library Development 2012–2014
At the end of 2014 the library of the Max
Finance had a total stack of more than
48,000 volumes. The traditional and major task of the library remains the optimal supply of information to all academics in all areas of research pursued at the
Institute. This continues to be reflected
in the huge increase in available books:
The library acquired more than 11,700
volumes in the reporting period.
It has become increasingly difficult to
store the growing library holdings in the
space available. In autumn 2014 preparations began to make the currently
closed stacks in the library’s basement
directly accessible to all users. This will
significantly enlarge the public access
areas. Up to now, journal volumes that
were published prior to 2005 have to be
ordered from the basement.
The library’s range of local information
provision is complemented by databases,
electronic journals and eBooks licensed
through the Max Planck Society’s centrally administered funds. Thus, the academic team has several thousand electronic
journals at their command, alongside a
multitude of legal and economic databases. In addition there is access to more
than half a million eBooks in all areas of
study. This includes an extensive product
range with publications from Elsevier,
Springer, DeGruyter, Duncker & Humblot,
Cambridge University Press and Oxford
University Press, among others.
Alongside the bibliographic information,
a fundamental strength of the library
catalogue is the ability to undertake
research in more than 35,000 tables of
contents for literature acquired since
2008 – for which the only location in
Germany or Europe where such amassed
information can be found is often our
library. In addition, not only are there
approximately 4,700 locally catalogued
eBooks as a research tool, but there are
also more than 500,000 eBooks contained in the MPG eBook catalogue.
Going beyond the classic fields of library
work, as a further service the management of the Institute’s publication data
has been reinforced. Thus, the recording
of publication data in the repository of
the Max Planck Society, MPG.PuRe, was
established as a key task.
Library
245
In 2012 Julia Sauerer successfully completed her training as a specialist in
media and information services, with a
focus on the library. With Carmen Diana
Holzer, the library has trained three specialists in media and information services
since 2012.
Librarian Petra Golombek in the
Institute‘s library, at Marstallstraße 8.
In 2014 a cooperation agreement was
concluded with the International Tax
Centre of the Bavarian State Ministry
for Finance, State Development and
Heritage (Internationalen Steuerzentrum, Bayerisches Staatsministerium der
Finanzen, für Landesentwicklung und
Heimat), extending the use of the library
to Bavarian tax officials. This cooperation
underlines the quality and significance
of the library’s unique collection, which
reaches beyond the boundaries of the
Institute.
The insolvency of the journal agency
“Swets” in September 2014 gave rise to
an unforeseeable challenge. In total, the
library obtained more than 120 journals
from this agency (of these, 44 were directed to the Max Planck Institute for
Tax Law and Public Finance). In all, 88
publishers were contacted in order to
obtain the outstanding issues. However,
completion of the 2014 collection will
not be achieved until well into 2015. For
some titles there is a risk that the 2014
volumes will not be acquired in full.
246 Services
Since 2013 Sabine Schmotz has been
committed to the enhancement of the
quality of training in Bavaria through
her activities as a speaker for the Quality Circle “FaMI” (Fachangestellte/r für
Medien- und Informationsdienste – specialist in media and information services)
Training in Bavaria). She maintains regular contact with the person responsible
for continuity training at the Bavarian
State Library and organises meetings of
all trainers.
A change in personnel had particular
impact on the library in the years 2012
and 2013. Ines Saler, the deputy head of
the library, went into retirement alongside another long-standing employee,
Susanne von Brescius. This made it necessary to undertake a comprehensive
reassignment of tasks as the position
of deputy head would no longer be
filled. Fortunately, the library team was
strengthened by Caterina Maul. However, at such short notice it was not possible
to fill a position that was responsible for
the library software, Aleph, and included
among its tasks the further development
of the library’s IT-based services.
2. External Activities and Training
The library maintains close ties with the
“Association for Law Library and Documentation Systems” (Arbeitsgemeinschaft für juristisches Bibliotheks- und
Dokumentationswesen) (AjBD). Peter
Weber, library director and member of
the board of the AjBD, was responsible
for the content of training events in 2013
and 2014 “eBooks in Law Libraries” and
“Visibility of Library Services in Law Libraries in the Digital Age”. These events
illuminated current issues in library work
and were each attended by more than
100 participants. Further, since June
2014 Peter Weber has been a member
of the “Legal Commission of the German
Librarians Club”, so that a close exchange
with colleagues from a great variety of
libraries has been maintained and support in respect of legal questions has
been provided to club members.
Further, Peter Weber was the speaker for
the Advisory Council for the Max Planck
Libraries. The Advisory Council serves to
represent the interests of the Max Planck
Society libraries as against the Max
Planck Digital Library, among others and
in addition organises the library sessions
of the Max Planck Society in consultation
with the Max Planck Digital Library.
Library staff took part in the following professional training sessions
2012
 Training: MPG Year Book from PubMan, Munich, 25.01. (Schmotz)
 Advisory Council Meeting, Bonn, 09.02. (Weber)
 Training: “Fit für die FaMI-Ausbildung”, Munich, 27.02. (Schmotz)
 XXXV Library Conference of the Max Planck Society, Heidelberg,
16.04.–18.04. (Saler, Schmotz, Weber)
 101st German Librarian Day, Hamburg, 22.05. –25.05. (Weber)
 Intercultural Basic Training, Garching, 19.06. –20.06. (Dolabdjian, Saler, Wockenfuss)
 Advisory Council Meeting, Halle, 10.07. (Weber)
 1st Working Session “Bibliothek 2025”, Marburg, 23.08.–24.08. (Weber)
 Advisory Council Meeting, Munich, 06.09. (Weber)
 Training “Fachenglisch an der Ausleihtheke”, Munich, 15.10. (Schmotz)
 eBook Workshop, Leipzig, 24.10.–25.10. (Weber)
 Training by AjBD and ViFa-Recht “Erschließung, Kataloganreicherung und Präsentation”, Berlin, 08.11.–09.11. (Weber)
Library
247
 Autumn Meeting of the Humanities Libraries, Jena, 13.11.–14.11.
(Saler, Weber)
 12th Conference of the Bavarian Library Association (BVB), Würzburg, 20.11. (Wockenfuss)
 Meeting of the Quality Circle for FaMI-Training in Bavaria, Munich 27.11. (Schmotz)
2013
 Advisory Council Meeting, Berlin, 28.01.–29.01. (Weber)
 5th Congress “Bibliothek und Information Deutschland”, Leipzig, 11.03.– 13.03. (Weber)
 2nd Working Session “Bibliothek 2025”, Würzburg, 21.03.–22.03. (Weber)
 XXXVI Library Conference of the Max Planck Society, Golm, 06.05.–08.05. (Schmotz, Weber)
 “Auskunft professionell gestalten – strukturelle und konzeptionelle
Aspekte”, Munich, 13.06. (Wockenfuss)
 Advisory Council Meeting, Göttingen, 25.06.–26.06. (Weber)
 Inauguration of the New Institute Building of the Max Planck Institute for European Legal History, Frankfurt, 02.09. (Weber)
 1st Meeting of the Working Group “Bibliothekskonzepte in der MPG”,
Berlin, 03.09. (Weber)
 34th Conference of the “Arbeitsgemeinschaft für Spezialbibliotheken”, Kiel, 10.09.–13.09. (Weber)
 “XML in Libraries”, Munich, 24.09.–25.09. (Wockenfuss)
 PubMan Days 2013, Munich, 23.10.–24.10. (Schmotz, Wockenfuss)
 Training of the AjBD “E-Books in juristischen Bibliotheken”, Koblenz, 07.11.–08.11. (Weber)
 Project Meeting “vLib-Nachfolge”, Munich, 07.11. (Schmotz)
 Meeting of the Quality Circle for FaMI-Training in Bavaria, Munich, 11.11.
(Schmotz)
 Autumn Conference of the Humanities Libraries, Leipzig, 11.11.–13.11. (Weber)
2014
 Advisory Council Meeting, Berlin, 30.01. (Weber)
 3rd Working Session “Bibliothek 2025”, Weimar, 05.02.–06.02. (Weber)
 Opening of the Library at Helmholtz-Centre Rossendorf, Dresden, 07.02. (Weber)
248 Services
 International Science 2.0 Conference, Hamburg, 26.03.–27.03. (Weber)
 Meeting of the Quality Circle for FaMI-Training in Bavaria, Nuremberg, 31.03. (Schmotz)
 XXXVII Library Conference of the Max Planck Society, Berlin, 12.05.–14.05. (Schmotz, Weber)
 103rd Librarian Day, Bremen, 03.06.–04.06. (Weber)
 Workshop “Bibliometrische Leistungsmessung in den Geistes- und Sozial-
wissenschaften”, Berlin, 15.07. (Weber)
 4th Working Session “Bibliothek 2025”, Eltville, 26.09.–27.09. (Weber)
 Workshop “Bibliothekskonzept” at the MPI for Empirical Aesthetics,
Frankfurt/Main, 29.09. (Weber)
 “Effektiv recherchieren im Internet”, Munich, 23.10.–24.10. (Dolabdjian, Wockenfuss)
 Training of the AjBD “Sichtbarkeit bibliothekarischer Dienstleistungen in juristischen Bibliotheken im digitalen Zeitalter”, Hamburg, 06.11.–07.11. (Weber)
 Autumn Conference of the Humanities Libraries, Bonn, 13.11.–14.11.
(Weber)
 14th Conference of the Bavarian Library Association (BVB), Rosenheim, 21.11. (Schmotz)
 Meeting of the Quality Circle for FaMI-Training in Bavaria, Munich, 24.11. (Schmotz)
Library
249
3. The Library in Numbers
The library of the Max Planck Institute for
Tax Law and Public Finance systematically and prospectively increases its inventory, which makes it an important centre
of attraction worldwide for researchers.
It is the library’s goal to offer academics
the best possible working conditions in
all areas of information supply. Due to
its sound financial endowment all significant publications have been made
available. The following figures provide
an overview over the acquisitions in
the reporting period, the currently held
journals and looseleaf services and the
development of the total inventory.
4,000
Acquisitions 2012
3,000
2,000
1,000
0
All media
types
Monographs
(purchased)
Monographs
(donated)
Periodicals
E-books
listed
Library for Tax Law
and Public Finance
4,099
2,768
394
370
567
Department of
Business and Tax Law
2,510
1,888
252
370
Department of
Public Economics
1,022
880
142
250 Services
The Library in Numbers
4,000
Acquisitions 2013
3,000
2,000
1,000
0
All media
types
Monographs
(purchased)
Monographs
(donated)
Periodicals
E-books
listed
Library for Tax Law
and Public Finance
4,133
2,434
286
330
1,083
Department of
2,199
1,776
93
330
851
658
193
Department of
Public Economics
4,000
Acquisitions 2014
3,000
2,000
1,000
0
All media
types
Monographs
(purchased)
Monographs
(donated)
Periodicals
E-books
listed
Library for Tax Law
and Public Finance
3,473
2,374
288
318
493
Department of
2,287
1,855
114
318
693
519
174
Department of
Public Economics
Library
251
The Library in Numbers
400
Currently Held Journals
and Looseleaf Services
300
200
100
0
Journals
Looseleaf
services
2012
221
141
2013
222
142
2014
218
134
50,000
Development of the
Total Inventory
40,000
30,000
20,000
10,000
0
Number of
volumes
Monographs
Journals
eBooks
2012
40,505
31,020
6,368
3,117
2013
44,638
33,740
6,698
4,200
2014
48,111
36,402
7,016
4,693
252 Services
4. Outlook
In the years to come, the desired comprehensive supply of information to the
research areas of the Institute, be it in
printed or electronic form, will continue
to have paramount priority. However, it
remains to be seen, particularly against
the backdrop of the development of the
Euro exchange rate, whether the library
will continue to be capable of making literature available in the necessary scope
in future, as we can assume that the costs
of literature, not only of Anglo-American
origin, will significantly increase.
We further intend to ensure that there is
a noticeable improvement in the use of
exclusively electronically sourced journals by introducing an appropriate pushservice, so that an electronic journal
circulation will be established for these
journals as well.
In the first quarter of 2015 a flat-bed
scanner will be made available in the
library for academics working at the Institute, with the help of which literature
can be quickly digitalised in a manner
that is at the same time non-invasive to
the physical book.
With the conclusion of the extension
works in the basement of the library in
the first half of 2015 the public access
section will be enlarged by 588 metres
of shelf space to a total of more than
1,600 metres of shelf space. This should
be recognised as a significant improvement in the effective use of the library. It
is only the archive for previous editions
that cannot be integrated into the public
access. There is a total of approximately
1,950 metres of shelf space available to
the library together with the archive of
former editions. Of these, almost 700
metres of shelf space are not occupied
and offer space for growth in the inventory over the next eight years.
A central task of the library will be to optimise access to the distributed electronic
resources that have been licensed by the
library or centrally from basic provision
funds for the Max Planck Society. The
decision, made in 2014, to offer a new
search platform should be implemented
in 2015. Via this discovery tool it will be
possible to search the unique inventory
of the library via an index with, at the
same time, as many electronic resources
from various publishing houses as possible. As part of a common project with
the Max Planck Institute for Comparative
and International Private Law (Hamburg),
the Max Planck Institute for Foreign and
International Criminal Law (Freiburg) and
the Max Planck Institute for Comparative Public Law and International Law
(Heidelberg) a solution should be implemented by exploiting the synergies that
enables each Institute to have both its
own access to the library data as well as
an Institute-specific parameterisation of
the search. A fundamental challenge will
be to prepare heterogeneous data for
such a search index so that qualitatively
valuable and comprehensible numbers
of matches are obtained.
Library
253
Meeting of the Scientific Advisory Board, 5–6 July 2012.
Scientific Advisory Board
Professor Robin W. Boadway, Ph.D.
Queen‘s University, Canada
Prof. Dr. Friedrich Breyer
University of Konstanz, Germany
Prof. Dr. Peter H. J. Essers
Tilburg University, Netherlands
 Professor Daniel Gutmann, Ph.D.
Université Paris 1, France
 Prof. Dr. Joachim Hennrichs
University of Cologne, Germany
Professor Michael Keen
International Monetary Fund, USA
Prof. Dr. Karl Ove Moene
University of Oslo, Norway
Prof. Dr. Kees van Raad
ITC Leiden University, Netherlands
Scientific Advisory Board
255
Meeting of the Board of Trustees 2014.
(left to right): Hendrik Wanger, Harald Lang, Erik Röder, Kai A. Konrad, Christian Thimann, Rudolf
Mellinghoff, Wolfgang Schön, Christoph M. Schmidt, Klaus P. Naumann, Franz-Christoph Zeitler,
Erik Hornung.
256 Services
Board of Trustees
 Prof. Dr. Alfred Bergmann
Presiding Judge, Federal Court of Justice
 Prof. Dr. Claudia M. Buch
Vice President, Deutsche Bundesbank
 Georg Fahrenschon
President, German Savings Banks Association
 Johannes Geismann
State Secretary, Federal Ministry of Finance

Heike Göbel
Frankfurter Allgemeine Zeitung
 Prof. Dr. rer. pol. Bernd Huber
President, Ludwig-Maximilians-Universität München
 Dr. Christian Kaeser
President, IFA Germany
 Prof. Dr. Han Kogels
Secretary General, International Fiscal Association
 Prof. Dr. h.c. Rudolf Mellinghoff
President, Federal Tax Court
 Prof. Dr. Klaus-Peter Naumann
Secretary General, Institute of Public Auditors
 Prof. Dr. Detlev Jürgen Piltz
President, IFA Germany
 Prof. Dr. Dr. Christoph M. Schmidt
President, Rheinisch-Westfälisches Institut für Wirtschaftsforschung
 Prof. Dr. Roman Seer
President, German Tax Law Association
 Dr. h.c. Wolfgang Spindler
Chairman German Auditor Oversight Commission
 Dr. Christian Thimann
Executive Committee, AXA Group
Prof. Frederick van der Ploeg, Ph.D.
Oxford Centre for the Analysis of Resource Rich Economies, University of Oxford
Prof. Dr. Franz-Christoph Zeitler
Former Vice President, German Central Bank
Board of Trustees
257
Imprint
Managing Director
Prof. Dr. Kai A. Konrad
Marstallplatz 1
80539 Munich, Germany
Phone: +49 89 24246-5250
Fax:
+49 89 24246-5299
Type-Setting
Christa Manta
Print
Druckerei Mayer & Söhne
Photographs and Graphics
David Ausserhofer (p. 126, Kai A. Konrad)
Nina Bonge (p. 128, 130, 131, 140, 142, 144 left, 250, 251, 252)
Zdenko Caganic (p. 236)
Athina Grigoriadou (p. 6, 146, 158, 170, 186, 243)
Christa Manta (p. 1 (title), 4, 7, 8, 10, 13 bottom, 16 bottom, 17 top, 18 top, 19 middle, 20 middle, 25, 27, 28, 29, 30, 43, 44, 49, 53, 58, 61, 62, 63, 65, 67, 135 top+ bottom, 137, 138 middle, 141,
149, 152, 155, 160, 164, 166, 246, 254, 256)
MPI (p. 41, 143, 144 right, 145, 147, 156, 162, 175, 180, 240, 241, 244)
Oxford Centre for Business Taxation (p. 26)
Gonçalo Silva (p. 143)
StBK München (p. 36, 46)
Markus Scholz for Leopoldina (p. 148)
WU Vienna (p. 38)
Report 2012 – 2014

Report 2012 – 2014 - Max-Planck-Institut für Steuerrecht und

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