The Multilateral Instrument: Avoidance of Permanent Establishment Status and the Reservations on behalf of Australia and the UK [PDF]
, 2013 This paper considers fully probabilistic system models. Each transition is quantified with a probability—its likelihood of occurrence. Properties are expressed as automata that either accept or reject system runs. The central question is to determine the
Ivanova, Milla
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The political economy of bilateralism and multilateralism : institutional choice in international trade and taxation [PDF]
, 2005 Trade relations are governed by the multilateral GATT, whereas the avoidance of international double taxation rests on a network of around 2000 bilateral treaties. Given the two regimes’ similar economic rationales this difference between bilateralism in
Rixen, Thomas, Rohlfing, Ingo
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The Dark Side of Transfer Pricing: Its Role in Tax Avoidance and Wealth Retentiveness [PDF]
, 2010 In conventional accounting literature, ?transfer pricing? is portrayed as a technique for optimal allocation of costs and revenues amongst divisions, subsidiaries and joint ventures within a group of related entities.
Abdel-Khalik +119 more
core +1 more source
Avoidance of Double Taxation Based on OECD Agreements: Analyze of the Albanian-Italian model
Mediterranean Journal of Social Sciences, 2014 Albania is already an indivisible part of the integration process in the European Union and in other international organizations, process which requires the implementation of the international agreements on the avoidance of the double taxation. The origin of the double taxation is in the conflict between the residence principle and source principle. It
openaire +2 more sources
The Canadian Arctic Sector: the Tide Under International Law
Московский журнал международного права, 2007 This article examines the legal foundation of Canadian claims to its Arctic Sector. In pursuing this goal the article focuses on the legal grounds, establishing Canadian rights in this sector and thus endorsed by the government of Canada.Several groups ...
A. N. Nikolaev, I. V. Bunik
doaj +1 more source
Defining the Relationship between Domestic General Anti-Avoidance Rules and Double Tax Agreements
, 2013 Double taxation agreements pose a particular analytical problem. While they provide a coherent structure that encourages cross-border investment, the agreements also provide opportunities for taxpayers to avoid their domestic tax obligations.
Cooper, Alexandra
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Tax Competition as a Challenge to the Governance of Global Economy [PDF]
, 2013 The paper analyses the role of tax competition in global economy. How can tax systems respond to the challenge - by international cooperation or by national rules, by tax harmonisation or by tax competition?
Kultalahti, Jukka, Penttilä, Seppo
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Defect Analysis of the β– to γ–Ga2O3 Phase Transition
Advanced Functional Materials, EarlyView.The role of defects at all the relevant stages of the β$\beta$‐ to γ$\gamma$‐Ga2O3 polymorph transition is investigated using a multi method approach. The positron annihilation spectroscopy based results show that the defect density decreases after the transition, and that changes in defect configuration within the γ phase occur with increasing ...
Umutcan Bektas +9 more
wiley +1 more source
From Waste to Value: Conversion of Calcium Sulfate to Vaterite via Carbon Capture and Storage
Advanced Functional Materials, EarlyView.This study introduces a new concept for carbon management that relies on the carbonation of industrial gypsum waste and yields phase‐pure vaterite at ambient conditions without any additives. The obtained vaterite is further shown to be a reactive material that develops compressive strength in aqueous suspensions like conventional cements.
Carlos Pimentel +4 more
wiley +1 more source
Analisis Tentang Beneficial Owner dalam Persetujuan Penghindaran Pajak Berganda Indonesia - Belanda dalam Sengketa Banding PT.Indosat., Tbk, di Pengadilan Pajak [PDF]
, 2018 Persetujuan Penghindaran Pajak Berganda Indonesia-Belanda dimaksudkan untuk membagi hak pemajakan atas penghasilan yang diperoleh penduduk Indonesia dan penduduk Belanda sehingga tidak terjadi pemajakan berganda (double taxation) dan atau pajak sama ...
Hasyim, S. (Syarifuddin) +2 more
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