Introduction / Reuven S. Avi-Yonah & Michael Lang -- European constitutional intergration : the case of direct taxation / Gianluigi Bizioli & Claudio Sacheto -- There is life in the old dog yet : horizontal comparability and the establishment of the internal market / Michael Lang --...

The OECD's public discussion draft ‘BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances' proposed a series of rules for the OECD model. The draft for Article X, ‘‘Entitlement to Benefits,'' the first five paragraphs of which are described therein as...