Results 41 to 50 of about 71,433 (310)

Reservations and declarations to tax treaties

open access: yesПравоприменение, 2021
The subject of the article. The article represents a research of conceptual properties and issues of applying reservations and declarations to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit ...
I. A. Khavanova
doaj   +1 more source

Base Erosion and Profit Shifting: A Simple Conceptual Framework [PDF]

open access: yesSSRN Electronic Journal, 2014
The issue of tax-motivated income shifting within multinational firms – or “base erosion and profit shifting” (BEPS) – has attracted increasing global attention and has become the subject of an ongoing OECD initiative. This paper provides a simple conceptual framework that helps to clarify aspects of governments’ responses to the BEPS phenomenon and ...
openaire   +3 more sources

Inflammatory Response‐Inspired Thermochromic Shield for Pneumatic Structures

open access: yesAdvanced Engineering Materials, EarlyView.
A thermochromic shield for pneumatic structures is developed, using anhydrous sodium acetate powder and thermochromic pigment‐included solution. In this shield composed of three layers, the exothermic and thermochromic reactions, followed by the mixture of both components, occur promptly with an incident of penetrating damage as a sign of initial ...
Hyun Jae Lee, Ryuma Niiyama
wiley   +1 more source

Dynamics of Base Erosion and Profit Shifting (BEPS) Tax Planning Strategy in the Global Sustainable Development Framework

open access: yesJurnal Perpajakan dan Keuangan Publik
Tax as the main source of income for the state has an important role in financing sustainable development. However, the dynamics of tax planning are increasingly complex with the issue of Base Erosion and Profit Shifting (BEPS), which has become a major ...
Fitri Pebriani Wahyu   +1 more
doaj   +1 more source

An analysis of the applicability of the OECD Model Tax Convention to non-OECD member countries: The South African case

open access: yesJournal of Economic and Financial Sciences, 2017
Most tax treaties (including South Africa's) are based on the OECD Model Tax Convention on Income and Capital and the related Commentary (the 'OECD Model').
Lee-Ann Steenkamp
doaj   +1 more source

The Taxation of Company Distributions in Respect of Hybrid Instruments in South Africa: Lessons from Australia and Canada

open access: yesPotchefstroom Electronic Law Journal, 2021
Tax legislation traditionally distinguishes between returns on investment paid on equity and debt instruments. In the main, returns on debt instruments (interest payments) are deductible for the paying company, while distributions on equity instruments ...
Liezel G Tredoux, Kathleen Van der Linde
doaj   +1 more source

Reflexiones acerca de un futuro Convenio multilateral en el ámbito de la Unión Europea [PDF]

open access: yes, 2015
Al hilo de la Acción 15 del Proyecto BEPS (Base erosion and profit shifting), liderado por la OCDE y el G-20, la autora plantea la posibilidad de adoptar un Convenio modelo en materia de renta y patrimonio en el ámbito de la Unión Europea, como preludio ...
Ribes Ribes, Aurora
core  

The impact of taxes on bilateral royalty flows [PDF]

open access: yes, 2015
In 2013 the OECD introduced its Action Plan on base erosion and profit shifting (BEPS). One of the major concerns of this Plan is a strategic use of intangible assets as an instrument for profit shifting.
Dudar, Olena   +2 more
core   +2 more sources

Population of Nonmetallic Inclusions in Liquid High‐Silicon Electrical Steel in Contact With MgO–C Refractories Based on Recyclates and Environmentally Friendly Binders

open access: yesAdvanced Engineering Materials, EarlyView.
The formation of nonmetallic inclusions (NMIs) was investigated in this study, carrying out immersion tests for 30 min at a temperature of 1600°C with liquid high‐silicon electrical steel (Si ≈ 3 mass‐%) and different MgO–C refractories. Conventional MgO–C refractories were considered, as well as MgO–C refractories containing MgO–C recyclate and ...
Lukas Neubert   +6 more
wiley   +1 more source

Preventing Tax arbitrage via Hybrid Mismatches: BEPS Action 2 and Developing Countries [PDF]

open access: yes, 2017
The Organization for Economic Cooperation and Development (OECD) under Base Erosion and Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements "result in a substantial erosion of the taxable bases of the countries
Dubut, Thomas   +8 more
core  

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