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Institutional Development in the Avoidance of Double Non-Taxation

2008
In the previous chapter, institutional choice in double tax avoidance was analysed. In this chapter, I broaden the perspective to include double nontaxation. I first briefly summarize the major developments in the fight against double non-taxation and show that they can be characterized as indirect and implicit changes in the international tax regime ...
Thomas Rixen
exaly   +2 more sources

Institutional Choice in the Avoidance of Double Taxation

2008
In this chapter, I construct an explanation for the institutional form of double tax avoidance by reconsidering and refining the baseline model of Chapter 3. First, I summarize the basic features of the institutional setup as the empirical account has revealed them in the language of rational choice institutionalism.
exaly   +2 more sources

The Future of Avoiding Double Taxation

2023
Abstract This chapter evaluates the future of avoiding double taxation. The two main methods of mitigating international double taxation—exemption and foreign tax credit—have been an essential part of international tax law since this area of law was established.
openaire   +1 more source

Avoiding Double Taxation: The Case of Commercial Banks

SSRN Electronic Journal, 2005
Recently, there has been a marked increase in the number of banks choosing to operate as Subchapter-S Corporations. The apparent motivation is tax savings as Subchapter-S firms do not pay federal income taxes on income at the firm level, but transfer income to stockholders where it is taxed as individual income at personal tax rates. Given the apparent
Ken B. Cyree   +2 more
openaire   +1 more source

Double Taxation Avoidance Agreements

SSRN Electronic Journal, 2012
The concept of double taxation has been the subject matter engaging the attention of the courts in India and abroad from time to time. The Supreme Court in Laxmipat Singhnia v. CIT has made it clear – “it is a basic rule of the law of taxation that unless otherwise expressly provided income cannot be taxed twice.
openaire   +1 more source

Primer on Double Taxation Avoidance Agreements

SSRN Electronic Journal, 2013
The writer has tried to analyse the articles of the United Nations Model Convention on the Double Taxation Avoidance Agreements. The Double Taxation Avoidance Agreements are bilateral agreements entered into between two states in order to avoid double taxation, i.e. The levying of tax by two different states on the same category of income. This article
openaire   +1 more source

Double Taxation Avoidance: International and Dividends

SSRN Electronic Journal, 2007
This paper is meant to be a chapter in an eventual book on EU taxation: a chapter which provides preliminary notions required for an understanding of the EU Parents-Subsidiary Directive. Before the parent-subsidiary directive can be studied, it is essential to have notions on international double taxation, the double taxation of dividends and all kinds
openaire   +1 more source

Double Taxation Avoidance Agreements in India

SSRN Electronic Journal, 2014
The double taxation avoidance agreement is an agreement which helps the taxpayer to get relief from double taxation on the same income. If India has signed any double taxation agreement with any foreign country; it’s meant that the taxpayer of those countries does not have to pay the tax on the same income in both the countries.
openaire   +1 more source

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