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Prof. Wolfgang Schön
WTS Award
Vienna LL.M.News
INTERNATIONAL
TAX LAW
VIENNA
WOLFGANG SCHÖN ON NEUTRALITY AND
TERRITORIALITY
Wolfgang Schön delivered the Klaus Vogel Lecture 2014 and
presented an analysis of the ECJ case law on the interaction
between the fundamental freedoms and national tax systems. He argued in favor of a strict application of a unilateral neutrality principle based on non-discrimination and
rejected those strands of case law which apply an overall
perspective to the taxation of cross-border events by two
(or more) states. He criticized the emerging trend in the
ECJ’s jurisprudence of stressing the territorial demarcation
of Member States’ taxing rights. Prof. Schön supports a
sophisticated application of the concept of “coherence” in
order to reconcile the requirements of neutrality with the
territorial limitations of taxing powers. Heinz-Klaus Kroppen,
who basically supported the positions taken by Prof. Schön,
provided comments.
The program of the day following the Klaus Vogel Lecture
was reserved for LL.M. alumni. In the morning, Prof. Alexander Rust gave a lecture on BEPS exclusively for LL.M. graduates. This was followed by the awards ceremony of the
WTS Award, presented by Fritz Esterer, Chief Executive
Klaus Vogel Lecture
www.international-tax-law.at
Prof. Heinz-Klaus Kroppen
Officer of WTS. All master’s theses submitted by students
who graduated in 2014 were eligible and a jury selected the
best three papers. The winners received prizes of EUR 2,500,
EUR 1,500 and EUR 1,000 for first, second and third place,
respectively.
In the afternoon, a group of graduates explored “Fantastic
Vienna”. “Fantastic realism“ is a special movement in late
modern art and one of the most successful export brands of
Austrian art. It is characterized by fantastical motifs from mythology and the world of dreams. The group started the tour
at the Phantasten Museum and enjoyed a presentation given
by Prof. Gott­hard Fellerer, an Austrian representative of the
Vienna School of Fantastic Realism. After a coffee break with
apple strudel at the Hofburg, the group visited the Ernst
Fuchs Museum. Ernst Fuchs, one of the representatives of
the Vienna School of Fantastic Realism, designed his own
museum in a villa constructed by the renowned Jugendstil
architect Otto Wagner.
The next Alumni Reunion is scheduled for
September 25-26, 2015. Please save the date!
At the Phantasten Museum
Apple strudel!
March 2015
In class
MY TAXBLOG WITH THE CANADIAN
TAX FOUNDATION: A TAX TALE OF THE
INTERTWINEMENT OF CULTURES AND
KNOWLEDGE
Jessica Di Maria
lenging, to say the least. They shook up my preconceived Canadian ideas of the tax world. Obviously,
this is expressly not “recounted” in the program’s
brochure. Amazed as I was by the challenges presented during my encounters in Vienna, I needed
to recount my “tax tales” to the Canadian tax community. And I did! Through a taxblog launched with
the support of the Canadian Tax Foundation.
Since the launch of the blog, the Canadian Tax
Foundation and I have been publishing one article
a month in which I report and comment on my
discussions with colleagues and tax professionals.
I am seeking to address frequently discussed tax
issues from a new angle… and bring a part of the
Canadian tax community with me to Vienna!
For more information:
http://www.ctf.ca/ctfweb/EN/Newsletters/
BLOGUE/BLOGUE_FISCAL_1.aspx
It is a well-known fact that the Vienna LL.M. program under the leadership of Prof. Michael Lang
and his team of renowned experts is second to
none in world. Its intensity, combined with its quality, results in education at the highest possible level.
Yet there is much more to discover during the program. As a former associate in a Canadian law firm,
my tax reasoning was once confined to the reflexes
one develops when practicing domestic tax law on
a daily basis. But Vienna has changed everything.
This is probably due to the subtle intertwinement
of cultures and knowledge offered by the LL.M.
program. Trust me: spending most of your time
with foreign students brings its share of animated
debates. Whether these take place in class, in a
Jessica Di Maria
pub, or while crammed in a night bus on the way to (Canada/Italy, Full-time 2014/15)
Prague, the discussions on critical tax issues chal-
JOB FAIR
Hosted by Prof. Michael Lang, the very first Career
Fair took place at the Institute of Austrian and
International Tax Law, exclusively for the current
students of the full- and part-time groups who will
finish the LL.M. Program in June. It was a unique
opportunity to get in touch with some of the leading firms, among which PwC and WTS.
Harshal Bhuta, India
Deloitte, E&Y, KPMG, LeitnerLeitner, PwC, TPA Horwath and WTS
www.international-tax-law.at
Carla Tovar, Panama
March 2015
Alumni
financial transactions became my hobby and I had
the chance to learn from experts during my threeOriginally from the Czech Republic, I completed my month secondment to Deloitte Belgium. During my
studies at the University of Economics in Prague.
work for Deloitte Vienna I had the opportunity to
Before my graduation, I started working for TPA
travel and meet amazing people; together with the
Horwath; TPA Horwath made it possible for me to
Austrian president, Dr. Heinz Fischer, and his busistudy in the LL.M. Program in Vienna. The program ness delegation, I travelled back to Vietnam; with
was an amazing experience; I was able to meet
the mayor of Vienna, Dr. Michael Häupl, and his
people from around the world and received great
business delegation, to Singapore and Hong Kong.
experience in my field (i.e. international tax), which Last year, one of my career dreams came true when
I was able to apply back in the Czech Republic.
I was given the opportunity to join ERSTE Group to
Andrea Lee
After five years at TPA Horwath in the Czech Rehead their transfer pricing department. After 15 years
public and Austria, I was seconded by the Horwath in consulting, it is amazing experience to be on the
Group to Shanghai, China, to manage their interother side, especially in an industry that I am very
national desk. After three years in China, I received passionate about. This not only gives me the opportuan offer from Deloitte to join their team in Vietnam. nity to acquire new knowledge and skills in the area of
During that time, transfer pricing became the hot
transfer pricing, but to get a deeper understanding of
topic in Vietnam so I accepted the challenge to
the banking industry. The timing could not have been
learn about this new area, establish a team and
better. With all the changes initiated by BEPS, it is exprovide transfer pricing services to our clients. I
citing to have the chance to implement them directly
was fortunate enough to also gain knowledge from in practice. It has been 13 years (!) since my LL.M.
colleagues in Singapore and Australia.
studies but I still keep in touch with friends from my
When I returned to Europe, I joined Deloitte
class and I always enjoy the annual alumni meetings.
Vienna and continued developing my skills in
transfer pricing, specializing in my favorite market
Andrea Lee
segment, financial institutions. Transfer pricing of
(Czech Republic, Full-time 2001/02)
FROM CZ TO CHINA AND VIETNAM
TURNING POINTS
Some decisions become turning points. It is still
very clear in my mind that the trigger that motivated me to take the LL.M. was my participation in a
project advising a client on the application of tax
treaties. During my years as a practitioner at E&Y
in Mexico, I realized that it was necessary to get
an understanding of the whole picture of international taxation. What I could not have imagined is
that the LL.M. would not only provide me with an
in-depth knowledge of international taxation, but it
would also open the door to first-hand experience
of a range of perspectives in the advisory business,
academia and tax policy in the government sector.
www.international-tax-law.at
After the LL.M., I was admitted to the Doctoral
program in International Business Taxation (DIBT
Program) in Vienna where I have had the opportunity to work as a researcher and lecturer in various
countries. After working as a tax advisor and being
able to explore the world in academia, I received a
unique opportunity to join in the tax treaty negotiation team from Liechtenstein. Now I can look at
the past and say that doing an LL.M. in Vienna was
not only in the right choice, but my turning point!
Daniel Fuentes Hernández
(Mexico, Full-time 2010/11)
Daniel Fuentes
Hernández
March 2015
Alumni / Miscellaneous
A FAIRYTALE WEDDING OR
LL.M. MEETS BOLLYWOOD
Saurab and his wife
My wedding commenced
with the auspicious ”Mehendi
Ceremony” in the afternoon,
where henna is applied to the
bride’s hands and feet. This
was followed by the “Sangeet
Ceremony” on the same day.
This was an evening full of
fun, food, and Bollywood. The
next morning saw the bride
and groom being covered with the traditional
“turmeric paste”, a part of the “Haldi Ceremony”.
The wedding ceremony took place at night in the
customary “Mandap” with the bride and groom
taking “7 Pheras” or rounds of the holy fire before
being pronounced husband and wife.
Saurab Arora (India, Full-time 2010/11)
WU BALL 2015
After having bought tickets for the WU Ball 2015
for my friend from Mumbai and myself, I was initially
a bit nervous: it was my first time at a ball and to
add to the nervousness, it was none other than the
renowned WU Ball!!! We armed ourselves by watching a few beginner waltz videos and then reached
the venue – the spectacular and beautifully lit-up
Hofburg Palace. We were welcomed by the wonderful inaugural dance performance in the Festival Hall.
The atmosphere was energetic, with a traditional
Viennese orchestra playing in the Festival Hall and
simultaneously different genres of music playing
in various halls of the Palace. We danced the waltz
along with numerous other couples in the Festival
Hall and, to our surprise, we did quite well! My most
memorable experience of the WU Ball 2015 will
always be the quadrille, which we attended after one
of our classmates assured us that no prior experience was required. Although the instructions were in
German, we quickly learned the steps by observing
others and as the pace of the orchestra increased,
it became more and more exciting! We bid adieu to
the WU Ball 2015 after the quadrille, taking pleasant
memories home with us.
Harshal Bhuta (India, Full-time 2014/15)
Part-time students
Full-time students
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Editorial staff: Prof. Michael Lang, Barbara Ender-Rochowansky
PARTNERS
www.international-tax-law.at
March 2015