On the relevance of double tax treaties. [PDF]
Int Tax Public Financ, 2020 AbstractThis paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network.
Petkova K, Stasio A, Zagler M.
europepmc +13 more sources
Withholding tax rates on dividends: symmetries versus asymmetries or single- versus multi-rated double tax treaties. [PDF]
Int Tax Public Financ, 2021 AbstractOut of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric (single-rated) and 59% are asymmetric (multi-rated), i.e., they prescribe different dividend withholding tax rates depending on the foreign investor’s ownership fraction.
Petkova K.
europepmc +4 more sources
Bilateral tax competition in double tax treaties between developed and developing countries. [PDF]
Int Tax Public FinancThis paper investigates tax competition in withholding tax rates signed under double tax treaties between developed and developing countries. We document a decline in average withholding tax rates since 1990 and attribute this trend to tax competition. As opposed to traditional tax competition, where every foreign investor benefits from lower tax rates,
Petkova K, Stasio A, Zagler M.
europepmc +2 more sources
The (un)certain future of tax sparing credit in international tax treaty law [PDF]
Anali Pravnog Fakulteta u Beogradu, 2022 Tax sparing clause emerged in double taxation treaties 63 years ago. Despite criticisms, it can presently be found in about 15% of all treaties, with Serbia having this clause in 46% of its double taxation agreements.
Popović Dejan, Ilić-Popov Gordana
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The Network of Bilateral Tax Treaties of the Slovak Republic – Does It Mirror Challenges of the Globalization through Digitalization? A Cluster Analysis Approach [PDF]
SHS Web of Conferences, 2021 Research background: Globalisations and movement of production factors - especially capital and workforces, call for elimination of double international juridical taxation and consequently for negotiation of bilateral tax treaties.
Kubicová Jana
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A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2022 As international trade is expanding, international trade and tax disputes are increasing. Under international tax agreements, there are two mechanisms for the resolution of potential disputes between contracting States.
Alireza Salehifar
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Arbitrability of International Tax Disputes [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2017 Over the past years, "arbitration" as a means of settling international disputes has gained popularity, but compared to international tax disputes, the possibility of applying the arbitration clause is disputed. After the successful use of arbitration to
Naeem Noorbakhsh +2 more
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Determining the Right Tax Jurisdiction in Bilateral Taxation Treaties and Preventing Abuse of the "Permanent Establishment" Concept [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2016 Bilateral tax treaties in the world are significantly spreading as a tool for waiver of double taxation, which is an obstacle in the way of expansion of international trade.
Gholam Nabi Feyzi Chekab +1 more
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Nationality non-discrimination in Serbian tax treaty law [PDF]
Anali Pravnog Fakulteta u Beogradu, 2014 This paper deals with the nationality non-discrimination provision in Serbian double taxation treaties. First the author analyses the historical development of the nationality non-discrimination clause found the in the OECD Model Tax Convention and ...
Kostić Svetislav V.
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Beneficial ownership of income as an antiabusive measure in Serbian Tax Law [PDF]
Zbornik Radova Pravnog Fakulteta u Nišu, 2020 The Serbian Corporate Income Tax Act contains a provision on the beneficial ownership of income (hereinafter: the BO provision), which is one of the conditions for the application of the preferential tax rate on income tax after tax deduction, which is ...
Vasović Miloš
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