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On the development of Russian tax treaty case law
ПравоприменениеThe research subject. This study focuses on recent developments (2021-2023) in Russian tax treaty case law.The purpose of the research. The objective of this research is to analyze the key trends and developments in tax treaty case law in Russia for the ...
E. V. Kilinkarova
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Direct Taxation in the European Union Countries (II)
CECCAR Business Review, 2021 The importance of the topic lies in the role played by taxation and fiscal reforms in this field for the economic development of the states around the globe especially as this paper focuses on the Member States of the European Union, which record ...
Maria-Cosmina PINȚEA
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Taxation of cross-border digital transactions: development of approaches to income classification
Правоприменение, 2021 The subject. The developing approaches towards the classification of various types of income received as a result of electronic transactions for the purposes of domestic tax legislation and double tax treaties at the level of international tax governance
N. S. Milogolov, A. B. Berberov
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Qualification of Hybrid Instruments in Double Tax Treaties [PDF]
Revista de Direito Tributário Internacional Atual, 2018 The internationalization of commercial trades and the process of globalization originated new financial instruments, which have both interest and dividend features, creating some barriers to qualify it for double tax treaties purposes. This complexity is enhanced by the reference to domestic legislation provided by art.
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Tax Treaty Interpretation in Spain [PDF]
, 2001 This paper provides insight in the interpretation of Spanish double taxation conventions. Taking as a premise the Vienna Convention on the Law of Treaties and the wording of Article 3(2) OECD Model Convention, the authors explore the relevance of mutual ...
Ribes Ribes, Aurora +1 more
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Direct Taxation in the European Union Countries (I)
CECCAR Business Review, 2021 The importance of the topic lies in the role played by taxation and fiscal reforms in this field for the economic development of the states around the globe especially as this paper focuses on the Member States of the European Union, which record ...
Maria-Cosmina PINȚEA
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Hybrid Finance in the Double Tax Treaties
SSRN Electronic Journal, 2008 The compartmentalisation of company finance into equity and debt does not truly capture the enormous diversity of financial instruments available. A wide variety of hybrid instruments incorporate elements of both equity and debt. From a fiscal point of view the classification of such hybrid instruments as equity or debt is crucial for two reasons ...
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The importance and effects of BEPS multilateral convention in international tax law [PDF]
Zbornik Radova Pravnog Fakulteta u Nišu, 2017 The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting is a result of the BEPS project carried out by the OECD and G20.
Popović Dejan, Ilić-Popov Gordana
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Taxation of Capital Gains in Spanish Tax Treaties: The Belgium-Spain Double Taxation Convention on Income and Capital [PDF]
, 2004 This paper is intended to analyse the treatment of capital gains in Spanish tax treaties. In particular, the author focuses on the new provision on the taxation of capital gains as a consequence of the alienation of shares in the Belgium-Spain double tax
Ribes Ribes, Aurora
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Double taxation conventions in Romania Case: DSSs Râşnov vs. ANAf braşov
Journal of Legal Studies, 2017 Conventions to avoid double taxation are the panacea of tax law, lato sensu, and direct taxation, stricto sensu. Although the current network of double taxation conventions has over 2500 tax treaties concluded by the world’s states, there are still ...
Dumiter Florin +2 more
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