Results 161 to 170 of about 1,889 (201)
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Intertax, 2021
The purpose of this work is to critically analyse the transposition of the Anti-tax Avoidance Directive (ATAD) (1 and 2) into the Spanish tax system. To do so, a distinction is made between the rules that are transposed (exit taxation, controlled foreign companies (CFCs) and hybrid mismatches) and those that are not (limitation on interest deductions ...
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The purpose of this work is to critically analyse the transposition of the Anti-tax Avoidance Directive (ATAD) (1 and 2) into the Spanish tax system. To do so, a distinction is made between the rules that are transposed (exit taxation, controlled foreign companies (CFCs) and hybrid mismatches) and those that are not (limitation on interest deductions ...
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Intertax, 2022
Germany has been an active supporter of the Base Erosion and Profit Shifting (BEPS) Project from its initiation and has also whole-heartedly supported the implementation of core BEPS recommendations in Europe through the anti-tax avoidance directive (ATAD). However, the subsequent domestic implementation process took longer than expected.
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Germany has been an active supporter of the Base Erosion and Profit Shifting (BEPS) Project from its initiation and has also whole-heartedly supported the implementation of core BEPS recommendations in Europe through the anti-tax avoidance directive (ATAD). However, the subsequent domestic implementation process took longer than expected.
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Article 6 ATAD and ‘Non-genuineness’ of Arrangements
EC Tax Review, 2021Article 6 Anti-Tax Avoidance Directive (ATAD) provides a General anti-abuse rule (GAAR), applicable to all taxpayers subject to corporate tax in one ormore EUMember States.TheGAAR refers to ‘non-genuine’ arrangements.However, it is unclear whether ‘non-genuineness’ describes real and/or simulated arrangements. The article aims to analyse this issue, in
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The ATAD's GAAR: A Pandora's Box?
SSRN Electronic Journal, 2017textabstractThis paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’): the general anti-abuse rule (‘GAAR’). The GAAR allows EU Member States to disregard for company tax purposes any non-genuine arrangements that have been put in place to defeat the object or purpose of applicable tax legislation with a view
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Transposition of ATAD GAAR in Belgium
2020In Belgium, the general anti abuse rule in matters of corporate income tax included in the anti-tax abuse directive has not been specifically transposed. We can however admit that the existing domestic rule against abuse in matters of income tax, viz. art. 344 § 1 of the Code of Income taxes, constitutes an adequate transposition.
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Air target algorithm development (ATAD)
Proceedings of the IEEE 1998 National Aerospace and Electronics Conference. NAECON 1998. Celebrating 50 Years (Cat. No.98CH36185), 2002The Combat Air Forces have invested heavily in a sensor and weapon capability to detect and attack air targets at long ranges. Unfortunately, the ability to identify these targets lags behind these capabilities. Under the Air Force sponsored Air Target Algorithm Development (ATAD) program, model-based reasoning (MBR) fusion algorithms have been ...
B. Overfield +5 more
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Sequential polymer dosing for effective dewatering of ATAD sludges
Water Research, 2005Dewatering problems associated with the sludge from autothermal thermophilic aerobic digestion (ATAD) of sludge, result in large chemical conditioning costs for effective dewatering. A variety of chemical conditioners were used to improve dewatering, but none of them were able to dewater the sludge as desired at acceptable conditioning doses.
Saurabh, Agarwal +2 more
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The ATAD’s Interest Limitation Rule – A Step Backwards?
European Taxation, 2019This article addresses the shortcomings of the interest limitation rule in the EU Anti-Tax Avoidance Directive (2016/1164).
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2019
The contribution analyzes whether and to what extent certain provisions of the ATA Directives, as implemented by Member States in their tax systems, might encroach the international tax obligations of the same Member States towards Third Countries and why such provisions might lead to the international responsibility of those Member States.
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The contribution analyzes whether and to what extent certain provisions of the ATA Directives, as implemented by Member States in their tax systems, might encroach the international tax obligations of the same Member States towards Third Countries and why such provisions might lead to the international responsibility of those Member States.
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