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CONSIDERATIONS ON THE PHENOMENON OF DOUBLE TAXATION IN THE EUROPEAN UNION [PDF]
In the general context of economic globalization, international economic cooperation, the liberalization movement of goods, services, capital and persons, and the effect of the exercise of fiscal sovereignty, appears the phenomenon of double or multiple ...
ALICE CRISTINA MARIA ZDANOVSCHI
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PROPAEDEUTICS OF THE LEGAL NATURE OF DOUBLE TAXATION AVOIDANCE AGREEMENTS [PDF]
Consideration of the legal nature of legal phenomena has both theoretical and practical significance. The first is to fill in the doctrinal content of the phenomenon being studied.
TROFIMOV V.A.
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International Double Taxation. Content, Consequences and Avoidance (I)
This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
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International Double Taxation. Content, Consequences and Avoidance (II)
This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
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Holding a Double Taxation Avoidance Agreement (P3B) or a Tax treaty is to avoid double taxation. The presence or absence of this tax treaty greatly affects investors’ profits in international trade transactions.
Firqotus Sa'idah, Tulus Suryanto
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Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]
The subject of the paper is an analysis of the issue of permanent establishment in the form of a dependent agent. The main purpose is to list the positive conditions leading to the setting up of a permanent establishment in the form of a dependent agent.
Agata Lipińska
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The article analyzes the situations that might limit the rights of a taxpayer under double taxation avoidance agreements. Because of the analysis of the national legislation in the area of taxation, significant differences that lead to the emergence of ...
Alexander Georgievich Gurinovich +2 more
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Double Taxation Treaty Interpretation: Lessons from a Case Down Under
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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Nationality non-discrimination in Serbian tax treaty law [PDF]
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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EDUCATIONAL MODELS FOR THE INTERNATIONAL CONTRACT FOR THE AVOIDANCE OF DOUBLE TAXATION - with emphasis on the countries of the Western Balkans [PDF]
The purpose of the manuscript is limited exclusively to assessing the role and legal nature of the international contract for the avoidance of double taxation.
Armand Krasniqi, Diamanta Sojeva
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