The true art of the tax deal: Evidence on aid flows and bilateral double tax agreements [PDF]
The World Economy, 2018 AbstractOf a total of 2,976 double tax agreements (DTAs), some 60% are signed between a developing and a developed economy. AsDTAs shift taxing rights from capital‐importing to capital‐exporting countries, the latter inherently benefit more from the agreements.
Braun, Julia, Zagler, Martin
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BEPS 2.0 Pillar I solutions on mechanisms of tax dispute resolutions
Prawo Budżetowe Państwa i Samorządu, 2023 The purpose of the article is to present the basic assumptions of Pillar I of BEPS 2.0 and to identify areas of potential disputes on the background of the application of the new mechanisms. The article will briefly outline preventive mechanisms aimed at
Małgorzata Duda-Plesińska
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A Note on Resolution of Tax Disputes Arising from DTTs and Implications for Developing Countries
Mizan Law Review, 2019 Countries sign bilateral double tax treaties (DTTs) to avoid or mitigate double taxation in cross border economic activity. It is hardly possible to ignore the effect of double taxation in the era of globalization.
Aschalew Ashagre Byness
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Tax Information Exchange Influence on Czech Based Companies’ Behavior in Relation to Tax Havens
Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2017 In recent years, borders between countries have been opened gradually thanks to globalization, which is reflected in minimal barriers to the movement of persons and capital.
Jan Rohan, Lukáš Moravec
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Theoretical and Practical Assessments of Transfer Prices. Legal Evidence from Romanian Case Law
Journal of Legal Studies, 2020 Transfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non ...
Dumiter Florin Cornel +1 more
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General Anti-Avoidance Rules and Double Tax Agreements: A New Zealand Perspective [PDF]
Revenue Law Journal, 2009 This article considers the effectiveness of the application of a general anti-avoidance rule (GAAR) when the impugned transaction or arrangement is cross-border. The vital issue is how a double tax agreement applies to the transaction or arrangement when the tax authorities invoke the GAAR.
Elliffe, Craig, Prebble, John
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Multilateral Convention (MLI) – Tax Evolution or Revolution?
Studia Iuridica Lublinensia, 2018 The Multilateral Convention (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) is an international agreement, which was signed on 7 June 2017 in Paris.
Agnieszka Franczak
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Resolution of dual residence instances in the case of companies [PDF]
Anali Pravnog Fakulteta u Beogradu, 2020 The application of double taxation treaties presupposes that the potential cases of dual residence have been previously resolved. For this purpose, the major model-conventions on the basis of which double taxation treaties around the globe are negotiated
Živković Lidija
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International Double Taxation. Content, Consequences and Avoidance (I)
CECCAR Business Review, 2020 This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
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International Double Taxation. Content, Consequences and Avoidance (II)
CECCAR Business Review, 2020 This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
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