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Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]
Societas et Iurisprudentia, 2021 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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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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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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Cross-border Intra-group Hybrid Finance and International Taxation [PDF]
, 2010 In intra-group finance hybrid instruments allow for tailor-made form of finance. Hence hybrid finance is often used for international tax planning in multinational groups. Due to a lack of international tax harmonization or tax coordination qualification
Eberhartinger, Eva +2 more
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Importance of double taxation to increase export potential of Georgia
Економіка, Eкологія, Cоціум, 2018 Introduction. According for future economic development of country and creation strong stable political framework is essential to improve international existing mechanism of avoiding double taxation.
Nazi Baratashvili, Zaza Pharsenadze
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Journal of Economic and Financial Sciences, 2014 This article investigates the legal status of Double Taxation Agreements, and the relationship between Double Taxation Agreements, which are concluded in terms of section 108 of the Income Tax Act, and the provisions of the Income Tax Act (taking into ...
David Costa, Lilla Stack
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Journal of Legal Studies, 2019 International double taxation represents one of the main problems’ for which taxpayers have to deal within a world fulfilled with globalization, uncertainty, risk, asymmetrical information and moral hazard. In this sense, in this article it is provided a
Dumiter Florin +2 more
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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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Technological and Economic Development of Economy, 2023 The topics approached in this paper are of interest due to the divergent opinions that emerged in the media academics and practitioners concerning how the double taxation conventions are constructed, the official language in which an international ...
Florin Cornel Dumiter
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Analele Ştiinţifice ale Universităţii "Al.I. Cuza" din Iaşi. Ştiinţe Juridice, 2021 Our study analyzes the hypothesis of distributing taxation competence in case of personal income tax. Traditionally, the individual is the beneficiary of a mobility in the capitalization of his labor force, mobility that can generate interferences of ...
Ioana Maria Costea
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