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Book Title: Elgar Encyclopedia of Comparative Law
Editor(s): Smits, M. Jan
Publisher: Edward Elgar Publishing
ISBN (hard cover): 9781845420130
Section: Chapter 65
Section Title: Tax Law
Author(s): Thuronyi, Victor
Number of pages: 10
Extract:
65 Tax law*
Victor Thuronyi
1 Introduction
The literature on comparative tax law is substantial, even though it repre-
sents only a small portion of the tax law literature. Most of it is descriptive
or, even if analytical, has a single-country focus. Such material might not
properly be considered as comparative, although it furnishes a good basis
for comparative study. Relatively few comparative studies are comprehen-
sive in scope.
The comparative tax literature is typically written by tax specialists,
rather than scholars of comparative law generally. This might be due to the
specialized nature of tax law. It has meant that comparative tax law schol-
arship has developed somewhat in isolation from comparative law scholar-
ship generally. Relatively few have published on comparative tax law and
the comparative dimension tends to be a relatively small part of their pro-
fessional life. The approach in much of the literature tends as a consequence
to be pragmatic.
Despite the limited development of comparative tax studies, the demand
for comparative knowledge of tax law is strong and increasing and the
actual use of comparative knowledge in law reform is substantial. This is
evidenced by substantial cross-jurisdictional borrowing of tax rules. EU
integration fuels some of the demand for comparative tax law knowledge.
At least the more sophisticated tax lawyers practising in the EU are
aware of the tax laws of other EU member states, and policymakers in EU
member states are aware of differences in country practice. Of course, tax
lawyers ...
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URL: http://www.austlii.edu.au/au/journals/ELECD/2006/216.html