Rechtsanwendungsprozesse im internationalen Steuerrecht

Based on the structuring doctrine of law („strukturierende Rechtslehre“), the author develops a model that depicts the actual process of applying the law in a processual way. One focus is on identifying the factors influencing the process of applying the law at different stages. At the same time, the problem of qualification conflicts in international tax law is presented as an example. This problem, in which two users of the law arrive at different results of their law application processes, is illuminated with the developed model. Exemplarily, the processes of applying the law in individual qualification conflicts are analyzed on the basis of the model.