Michael Lang
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View article: Acordos de Dupla Tributação e Direito Constitucional
Acordos de Dupla Tributação e Direito Constitucional Open
Acordos de Dupla Tributação e Direito Constitucional
View article: AI Conversational Interviewing: Transforming Surveys with LLMs as Adaptive Interviewers
AI Conversational Interviewing: Transforming Surveys with LLMs as Adaptive Interviewers Open
View article: Withholding Taxes, Losses and Territoriality -Opinion Statement ECJ-TF 3/2025 on the decision of the CJEU of 19 December 2024 in Case C-601/23, Credit Suisse Securities (Europe) Ltd v Diputación Foral de Bizkaia
Withholding Taxes, Losses and Territoriality -Opinion Statement ECJ-TF 3/2025 on the decision of the CJEU of 19 December 2024 in Case C-601/23, Credit Suisse Securities (Europe) Ltd v Diputación Foral de Bizkaia Open
View article: EU Report
EU Report Open
View article: Nordcurrent Group: Interpretation of the Anti-abuse Provision in the Parent Subsidiary Directive&nbsp;<div> Opinion Statement ECJ-TF 2/2025 on the Decision of the CJEU of 03 April 2025 in Case C-228/24, Nordcurrent Group UAB</div>
Nordcurrent Group: Interpretation of the Anti-abuse Provision in the Parent Subsidiary Directive Opinion Statement ECJ-TF 2/2025 on the Decision of the CJEU of 03 April 2025 in Case C-228/24, Nordcurrent Group UAB Open
View article: Legal Professional Privilege and the Validity of Certain Provisions of DAC6 in light of the Charter of Fundamental Rights of the European Union -Opinion Statement ECJ-TF 1/2025 on the CJEU Decision of 8 December 2022 in Orde van Vlaamse Balies (Case C-694/20) and of 29 July 2024 in Belgian Association of Tax Lawyers (Case C-623/22)
Legal Professional Privilege and the Validity of Certain Provisions of DAC6 in light of the Charter of Fundamental Rights of the European Union -Opinion Statement ECJ-TF 1/2025 on the CJEU Decision of 8 December 2022 in Orde van Vlaamse Balies (Case C-694/20) and of 29 July 2024 in Belgian Association of Tax Lawyers (Case C-623/22) Open
View article: AI Conversational Interviewing: Transforming Surveys with LLMs as Adaptive Interviewers
AI Conversational Interviewing: Transforming Surveys with LLMs as Adaptive Interviewers Open
Traditional methods for eliciting people's opinions face a trade-off between depth and scale: structured surveys enable large-scale data collection but limit respondents' ability to voice their opinions in their own words, while conversati…
View article: Alleged State Aid in Relation to a Deduction/Non-Inclusion Structure in Luxembourg – Opinion Statement ECJ-TF 1/2024 on the Decision of the CJEU of 5 December 2023 in Engie (Joined Cases C-451/21P and C-454/21P)
Alleged State Aid in Relation to a Deduction/Non-Inclusion Structure in Luxembourg – Opinion Statement ECJ-TF 1/2024 on the Decision of the CJEU of 5 December 2023 in Engie (Joined Cases C-451/21P and C-454/21P) Open
In this CFE Opinion Statement, submitted to the EU Institutions in February 2024, the CFE ECJ Task Force comments on the CJEU’s decision of 5 December 2023 in Engie (Joined Cases C-451/21P and C-454/21P), which addressed alleged State aid …
View article: Regulating mobile health research in Canada: Public trust and public participation
Regulating mobile health research in Canada: Public trust and public participation Open
Smartphone applications provide unique opportunities for health research. Prospective participants may be recruited, give consent, and may share personal health information with researchers with unparalleled efficiency. Mobile health apps …
View article: Apple's Case: State aid concerning the (mis)allocation of profits to Irish PEs Opinion Statement ECJ-TF 2/2024 on the decision of the CJEU of 10 September 2024 in Joined Cases C-465/20 P, Commission v Ireland and Others
Apple's Case: State aid concerning the (mis)allocation of profits to Irish PEs Opinion Statement ECJ-TF 2/2024 on the decision of the CJEU of 10 September 2024 in Joined Cases C-465/20 P, Commission v Ireland and Others Open
View article: Right To Be Paid Interest on Overpayment of Taxes in Breach of EU Law – Opinion Statement ECJ-TF 3/2023 on the CJEU Decision of 8 June 2023 in E. v. Dyrektor Izby Administracji Skarbowej we Wrocławiu (Case C-322/22)
Right To Be Paid Interest on Overpayment of Taxes in Breach of EU Law – Opinion Statement ECJ-TF 3/2023 on the CJEU Decision of 8 June 2023 in E. v. Dyrektor Izby Administracji Skarbowej we Wrocławiu (Case C-322/22) Open
In this CFE Opinion Statement, submitted to the EU Institutions on 4 October 2023, the CFE ECJ Task Force comments on the CJEU’s decision of 8 June 2023 in E. v Dyrektor Izby Administracji Skarbowej we Wrocławiu (Case C-322/22), which addr…
View article: Lexical Variation and Change
Lexical Variation and Change Open
Distributional semantics embodies the idea that the context in which a word occurs reveals the meaning of that word. In contemporary corpus linguistics, that idea takes shape in various types of quantitative context analysis. This monograp…
View article: The Application of the Multilateral Instrument (MLI) “Alongside Existing Tax Treaties”
The Application of the Multilateral Instrument (MLI) “Alongside Existing Tax Treaties” Open
View article: Accessory Tax Obligations Imposed on Digital Service Providers, Opinion Statement ECJ-TF 2/2023 on the ECJ Decision of 22 December 2022 in Airbnb Ireland and Airbnb Payments UK (Case C-83/21)
Accessory Tax Obligations Imposed on Digital Service Providers, Opinion Statement ECJ-TF 2/2023 on the ECJ Decision of 22 December 2022 in Airbnb Ireland and Airbnb Payments UK (Case C-83/21) Open
In this CFE Opinion Statement, submitted to the EU Institutions in June 2023, the CFE ECJ Task Force comments on the ECJ decision in Airbnb Ireland and Airbnb Payments UK (Case C-83/21), wherein the Court decided, inter alia, that it was c…
View article: Cancer Risk Prediction Regulation Models: Canada Contrasted with the U.S. and the E.U.
Cancer Risk Prediction Regulation Models: Canada Contrasted with the U.S. and the E.U. Open
Risk prediction models hold great promise to reduce the impact of cancer in society through advanced warning of risk and improved preventative modalities. These models are evolving and becoming more complex, increasingly integrating geneti…
View article: Opinion Statement ECJ-TF 4/2022 on the ECJ Decision of 22 September 2022 in W AG (Case C-538/20) on the Deductibility of Foreign Final Losses
Opinion Statement ECJ-TF 4/2022 on the ECJ Decision of 22 September 2022 in W AG (Case C-538/20) on the Deductibility of Foreign Final Losses Open
In this CFE Opinion Statement, submitted to the EU Institutions in November 2022, the CFE ECJ Task Force comments on the ECJ decision of 22 September 2022 in W AG (Case C-538/20), on the deductibility of foreign final losses.
View article: Opinion Statement ECJ-TF 3/2022 on the EFTA Court Decision of 1 June 2022 in PRA Group Europe (Case E-3/21), on the Discriminatory Interaction between the “Interest Barrier” and Group Contributions
Opinion Statement ECJ-TF 3/2022 on the EFTA Court Decision of 1 June 2022 in PRA Group Europe (Case E-3/21), on the Discriminatory Interaction between the “Interest Barrier” and Group Contributions Open
In this CFE Opinion Statement, the CFE ECJ Task Force comments on the EFTA Court decision of 1 June 2022 in PRA Group Europe (Case E-3/21), on the discriminatory interaction between the “interest barrier” and group contributions.
View article: Opinion Statement ECJ-TF 4/2023 on the decision of the EFTA Court of 4 July 2023 in Case E-11/22, RS - Compatibility with fundamental freedoms of a municipal surcharge distinguishing between residents and non-residents for the purposes of the applicable rate
Opinion Statement ECJ-TF 4/2023 on the decision of the EFTA Court of 4 July 2023 in Case E-11/22, RS - Compatibility with fundamental freedoms of a municipal surcharge distinguishing between residents and non-residents for the purposes of the applicable rate Open
View article: Peer Review #1 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.2)"
Peer Review #1 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.2)" Open
Background.Asymmetric genitalia have repeatedly evolved in animals, yet the underlying causes for their evolution are mostly unknown.The fruit fly Drosophila pachea has asymmetric external genitalia and an asymmetric phallus with a right-s…
View article: Peer Review #1 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.1)"
Peer Review #1 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.1)" Open
Background.Asymmetric genitalia have repeatedly evolved in animals, yet the underlying causes for their evolution are mostly unknown.The fruit fly Drosophila pachea has asymmetric external genitalia and an asymmetric phallus with a right-s…
View article: Peer Review #3 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.1)"
Peer Review #3 of "No evidence for asymmetric sperm deposition in a species with asymmetric male genitalia (v0.1)" Open
Background.Asymmetric genitalia have repeatedly evolved in animals, yet the underlying causes for their evolution are mostly unknown.The fruit fly Drosophila pachea has asymmetric external genitalia and an asymmetric phallus with a right-s…
View article: Opinion Statement ECJ-TF 2/2022 on the Decision of 27 January 2022 in European Commission v. Kingdom of Spain (Form 720) (Case C-788/19)
Opinion Statement ECJ-TF 2/2022 on the Decision of 27 January 2022 in European Commission v. Kingdom of Spain (Form 720) (Case C-788/19) Open
In this CFE Opinion Statement, the CFE ECJ Task Force comments on the decision of 27 January 2022 in European Commission v. Kingdom of Spain (Form 720) (Case C-788/19) on the lack of proportionality of the consequences derived from the fai…
View article: Author Index
Author Index Open
View article: Opinion Statement ECJ-TF 1/2022 on the ECJ Decision of 25 November 2021 in État Luxembourgeois v. L (Case C-437/19) on the Conditions for Information Requests and Taxpayer Remedies
Opinion Statement ECJ-TF 1/2022 on the ECJ Decision of 25 November 2021 in État Luxembourgeois v. L (Case C-437/19) on the Conditions for Information Requests and Taxpayer Remedies Open
In this CFE Opinion Statement, the CFE ECJ Task Force comments on the ECJ decision in État luxembourgeois v. L (Case C-437/19) of 25 November 2021. This decision brings further clarification on the rights of information holders in respect …
View article: The Principle of Territoriality and its Implementation in the Proposal for a Council Directive on a Common Consolidation Corporate Tax Base (CCCTB)
The Principle of Territoriality and its Implementation in the Proposal for a Council Directive on a Common Consolidation Corporate Tax Base (CCCTB) Open
This paper was completed on 28 March 2012 and is based on the author’s lecture on 7 October 2011 at the University of Florida.The EU Commission put forward its proposal for a Directive for a Common Consolidated Corporate Tax Base ("CCCTB")…
View article: Diving after COVID-19: an update to fitness to dive assessment and medical guidance
Diving after COVID-19: an update to fitness to dive assessment and medical guidance Open
View article: Opinion Statement ECJ-TF 3/2021 on the ECJ Decision of 19 March 2021 in MK v. Autoridade Tributária e Aduaneira (Case C-388/19) on the Option of Taxpayers to Avoid Discriminatory Taxation of Capital Gains
Opinion Statement ECJ-TF 3/2021 on the ECJ Decision of 19 March 2021 in MK v. Autoridade Tributária e Aduaneira (Case C-388/19) on the Option of Taxpayers to Avoid Discriminatory Taxation of Capital Gains Open
In this CFE opinion statement, the CFE ECJ Task Force comments on the ECJ decision in MK v. Autoridade Tributária e Aduaneira (Case C-388/19) of 18 March 2021. The Court confirmed its previous case law and held that the Portuguese (optiona…
View article: Opinion Statement ECJ-TF 4/2022 on the ECJ Decision of 22 September 2022 in Case C-538/20, W AG, on theDeductibility of Foreign Final Losses
Opinion Statement ECJ-TF 4/2022 on the ECJ Decision of 22 September 2022 in Case C-538/20, W AG, on theDeductibility of Foreign Final Losses Open
View article: Opinion Statement ECJ-TF 2/2022 on the CJEU decision of 27 January 2022 in Case C-788/19, European Commission v Kingdom of Spain (Form 720), on the Lack of Proportionality of the Consequences Derived from the Failure to Provide Information Concerning Assets or Rights Held in Other Member States of the European Union or the EEA
Opinion Statement ECJ-TF 2/2022 on the CJEU decision of 27 January 2022 in Case C-788/19, European Commission v Kingdom of Spain (Form 720), on the Lack of Proportionality of the Consequences Derived from the Failure to Provide Information Concerning Assets or Rights Held in Other Member States of the European Union or the EEA Open
View article: Art 16 OECD Model Convention and Board Members with Managerial Tasks
Art 16 OECD Model Convention and Board Members with Managerial Tasks Open
Article 16 OECD MC that deals with "directors' fees".Outside of the German-speaking countries, it is widely undisputed that this provision also includes fees paid to directors who perform managerial tasks in their capacity as a member of a…