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This work is the result of a conference held in September 1996 in
Germany in honour of Professor Hiroshi Kaneko, Emeritus Professor
of Tokyo State University. Some 60 scholars and practitioners of
international tax law from Japan and Germany convened to discuss
questions of common interest. The first part of the book explores
the methods of interpretation of tax statutes and treaties used in
both countries, particularly in light of the totally different
structure of the Japanese language as compared to European
languages. Such differences may be of potentially significant
importance to the interpretation of tax treaties, usually concluded
in two authentic language versions which are equally binding. The
papers in the second part present a detailed analysis of issues of
international transfer pricing in Germany and in Japan,
highlighting important differences as well as surprising
similarities of the two legal systems. The collection of expert
papers provides an important contribution to the literature in the
field of international and comparative taxation. For the tax
practitioner it should be useful reading when he or she is
confronted with Japanese tax treaties, the interpretation of which
is contested, or with transfer pricing problems in connection with
Japan.
Constructional morphology explains features of organisms from a
constructional and functional point of view. By means of physical
analysis it explains the operational aspects of organic structures
- how they can perform the activities organisms are expected to
fulfil in order to survive in their environment. Constructional
morphology also explains options and constraints during the
evolution determined by internal constructional needs, ontogenetic
demands, inherited organizational preconditions and environmental
clues.
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