Results 11 to 20 of about 66,750 (206)
Taxation of capital gains of companies from the alienation of shares [PDF]
Anali Pravnog Fakulteta u Beogradu, 2017 The paper deals with the tax treatment of capital gains on shares of companies both in national and tax treaty law. The authors indicate that the authentic interpretation of the Art.
Popović Dejan, Ilić-Popov Gordana
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Double Taxation Treaty Interpretation: Lessons from a Case Down Under
Potchefstroom Electronic Law Journal, 2020 In the Australian case of Bywater Investments Ltd v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation (the Bywater case) the Australian High Court dealt with the question of whether certain companies were resident in Australia for
Izelle du Plessis
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The Role of Tax Treaties in Facilitating Development and Protecting the Tax Base [PDF]
, 2014 The amount of taxes paid by multinational enterprises (MNEs) in host and home countries continues to make headline news. Corporate tax regimes, particularly those in many OECD countries, have never been more complex and the competition to attract and ...
Lang, Michael, Owens, Jeffrey
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Reservations and declarations to tax treaties
Правоприменение, 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
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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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Analysis of anti-avoidance measures in the tax system of the post-Soviet countries
Модернизация, инновация, развитие, 2023 Purpose: of the article is to analyze anti-avoidance measures within the international tax policy and national tax systems of the countries of the post-Soviet space based on the provisions of the BEPS plan and other international events.Methods: the ...
I. A. Zhuravleva
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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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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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Advance Pricing Agreements and Double Taxation – Key Concepts in the Context of Transfer Pricing [PDF]
Ovidius University Annals: Economic Sciences Series, 2017 The paper presents the main advantages and disadvantages of an advance pricing agreement (APA), illustrates a practical example regarding a situation of double taxation of results and presents a comparative analysis between the number of advance pricing ...
Ignat (Neacsu) Ioana
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Правоприменение, 2022 The subject. The specifics of the functioning of tax systems and the risk of double taxation require a solution to the issue of whether tax competence can remain only at the national level.
E. A. Ponomareva
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