Comparative Tax Law

This chapter discusses comparative tax law. The basic purpose of comparative law (including that of comparative tax law) is knowledge of foreign and national law: comparative law looks at different rules and institutions to establish to what extent they are similar or different. A curious and well-known result of comparative law is that it may lead to a better understanding of the law of one’s own country and its evolution by comparison with other legal systems. The boundaries of comparative tax law, however, are not easily defined. Comparative tax law may be applied to income tax, VAT, inheritance tax, and other taxes or compulsory contributions with regard to the specific rules, institutions, and structures of a certain tax. The chapter discusses the methods of comparative tax law, looking at how to compare and encompass the identification of sources of law, the study of foreign law, and real comparison. The chapter also considers tax models.