Herausforderungen bei Doppelbesteuerungsabkommen zwischen Industrie- und Schwellenstaaten.

»Challenges of Double Tax Treaties between Industrialized and Emerging Countries. The Principle of State Performance using the Example of the Double Taxation Treaty between Germany and Vietnam« The author developed an international tax principle that allows an appropriate distribution of tax revenues under tax treaty law between industrialized and developing / emerging countries. The principle is based on the ability of the state to levy taxes. It corrects certain effects of the current ruling principle of economic allegiances. Its application is simulated and evaluated on the basis of a permanent establishment triangular case (Germany/Vietnam/Japan).