Arbeitnehmerentsendungen im internationalen Ertragsteuerrecht

Secondments form an essential link between domestic and foreign group companies. Thus, the taxation of secondments affects both the employee and employer as well as several tax jurisdictions. This results in a considerable complexity of the taxation of secondments, which in turn creates various tax risks for all parties involved. The thesis systematically presents the taxation consequences of secondments, embeds them in an overarching economic and legal framework, and critically evaluates various norms of national tax law and treaty law.