Results 11 to 20 of about 394 (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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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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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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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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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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Not Just for Americans: The Case for Expanding Reciprocal Tax Exemptions for Foreign Investments by Pension Funds [PDF]
The School of Public Policy Publications, 2014 From provision of OAS, GIS and CPP to the favourable taxation of Registered Pension Plans and RRSPs , Canada’s government has long focused policy efforts on better ensuring that working Canadians approach retirement with sufficient income supports in ...
Jack M. Mintz, Stephen R. Richardson
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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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European Union, cross-border business activities and treaties on avoiding double taxation [PDF]
Megatrend Revija, 2018 The development of the European Community and the founding of the European Union (EU) led to the new legal order in Europe. Supremacy of the EU law, Community loyalty, fundamental freedom and the principle of non-discrimination caused specific treatment ...
Stojanović Snežana R.
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