The Institutional Design of International Double Taxation Avoidance [PDF]
SSRN Electronic Journal, 2008 This article analyzes the institutional design of international double tax avoidance. The basic argument is that double tax avoidance exhibits the strategic structure of a coordination game with a distributive conflict. The distribution of tax revenues depends on the asymmetry of investment flows between treaty partners.
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Importance of double taxation to increase export potential of Georgia
Економіка, Eкологія, Cоціум, 2018 Introduction. According for future economic development of country and creation strong stable political framework is essential to improve international existing mechanism of avoiding double taxation.
Nazi Baratashvili, Zaza Pharsenadze
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Правоприменение, 2023 Subject of research. The article is dedicated to the “tax treaty override”; it outlines debatable aspects, associated herewith. “Tax treaty override” is an action (in certain cases - omission of action) to expand taxation beyond (jurisdictional ...
I. A. Khavanova
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Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]
Societas et Iurisprudentia, 2021 The subject of the paper is an analysis of the issue of permanent establishment in the form of a dependent agent. The main purpose is to list the positive conditions leading to the setting up of a permanent establishment in the form of a dependent agent.
Agata Lipińska
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Double taxation conventions in Romania Case: DSSs Râşnov vs. ANAf braşov
Journal of Legal Studies, 2017 Conventions to avoid double taxation are the panacea of tax law, lato sensu, and direct taxation, stricto sensu. Although the current network of double taxation conventions has over 2500 tax treaties concluded by the world’s states, there are still ...
Dumiter Florin +2 more
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The Concept of Beneficial Owner in Application of the Ukrainian Double Taxation Treaties [PDF]
, 2016 The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of application of the provisions of double-taxation treaties since the adoption of the Tax Code of Ukraine, in 2010.
Selezen, Pavlo, Tymchenko, Leonid
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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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FDI and Tax Policy: Evidence from Indonesia [PDF]
E3S Web of Conferences, 2023 Foreign Direct Investment (FDI) is an investment from one country into another country. The purpose of this research is to determine the factors that affect the FDI inward in Indonesia. The research object used is the condition of FDI in Indonesia within
Prawati Levana Dhia +2 more
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Extending taxation of interest and royalty income at source : an option to limit base erosion and profit shifting? [PDF]
, 2014 This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation.
Finke, Katharina +3 more
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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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