Besteuerung von Mitarbeiterbeteiligungen beim Wechsel der persönlichen Steuerpflicht

This dissertation closes a previously underexplored gap in international tax law and provides valuable guidance for both practice and scholarship. It is the first systematic study of the tax treatment of employee participation schemes when personal tax status or treaty residence changes. The analysis covers the full range of employee participation schemes, develops the general principles of employee taxation, and brings together domestic income tax law and the law of double taxation conventions. The author is an attorney, tax adviser, and specialist lawyer for tax law.