Results 211 to 220 of about 5,803 (249)
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SSRN Electronic Journal, 2013
Since WW II there has been a rapid expansion in the number of bilateral double tax agreements (DTAs) concluded between countries. A feature of modern DTA negotiations has been the adoption of internationally accepted models or templates from which most DTAs are negotiated from. Although such models were in existence prior to WW II, it was not until the
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Since WW II there has been a rapid expansion in the number of bilateral double tax agreements (DTAs) concluded between countries. A feature of modern DTA negotiations has been the adoption of internationally accepted models or templates from which most DTAs are negotiated from. Although such models were in existence prior to WW II, it was not until the
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Double Tax Agreements – More Sword than Shield
International Transfer Pricing Journal, 2019The recent decision hailed as reaffirming Australia’s right to tax royalties under the Australia-India double tax agreement (DTA) was delivered by the Full Federal Court in the case of Satyam. The decision highlights the role played by the relevant DTA in combination with the Assessment Act to reiterate Australia’s position that it has the right to tax
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Economic Analysis of India's Double Tax Avoidance Agreements
SSRN Electronic Journal, 2010Bilateral Double Taxation Avoidance Agreements (DTAAs) with particular reference to India's network of DTAAs are analysed here to assess national benefits from DTAAs and make suggestions for future policy directions for India's DTAAs. Though DTAAs are a tool of tax coordination used by nations to apportion tax bases in the global fiscal commons, there ...
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SSRN Electronic Journal, 2016
The paper illustrates a discrepancy between the Act of Parliament and the narrative offered by the Australian Tax Office on the changes introduced since July 2009 with reference to Income Tax Assessment Act 1936 – S23AG. This pertains to the Double Tax Avoidance Agreements (DTAA) of which Australia is a signatory. The DTAA with Singapore is taken as an
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The paper illustrates a discrepancy between the Act of Parliament and the narrative offered by the Australian Tax Office on the changes introduced since July 2009 with reference to Income Tax Assessment Act 1936 – S23AG. This pertains to the Double Tax Avoidance Agreements (DTAA) of which Australia is a signatory. The DTAA with Singapore is taken as an
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How to Axe a Double Taxation Avoidance Agreement: Analysing Section 94A of the Indian Income Tax Act
Intertax, 2016Section 94-A of the Indian Income Tax Act, which allows the Indian government (the executive) to notify any jurisdiction, by having regard to the lack of effective exchange of information with it, as a notified jurisdictional area (NJA) has been a bone of contention in a recent ruling delivered by the Madras High Court in India in T.
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2023
Many countries of the world have signed bilateral tax treaties to avoid or mitigate double taxation and control tax evasion and planning in cross-border economic activities. However, such networks of bilateral tax treaties have in effect opened room for tax treaty shopping.
Adugna, Alemu, Adugna, Alemu
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Many countries of the world have signed bilateral tax treaties to avoid or mitigate double taxation and control tax evasion and planning in cross-border economic activities. However, such networks of bilateral tax treaties have in effect opened room for tax treaty shopping.
Adugna, Alemu, Adugna, Alemu
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Fight against double taxation and abuse of tax agreements
Право и государство: теория и практика, 2022openaire +1 more source
European Financial Resilience and Regulation
This paper aims to clarify how the provisions of Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms in the European Union should be understood and applied. This directive is supplemented by the provisions of its Implementing Regulation (EU) 2019/652 of the Commission, adopted on April 24, 2019, which establishes the standard ...
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This paper aims to clarify how the provisions of Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms in the European Union should be understood and applied. This directive is supplemented by the provisions of its Implementing Regulation (EU) 2019/652 of the Commission, adopted on April 24, 2019, which establishes the standard ...
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Double tax agreements and international allocation of business income in Australia
1999Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double ...
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