Results 11 to 20 of about 4,439 (164)

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
doaj   +1 more source

The relationship between Double Taxation Agreements and the provisions of the South African Income Tax Act

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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Avoiding Double Taxation Through The Assessment of International Tax Treties. Case: ESP’s versus Anaf Braşov

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, Jimon Ștefania Amalia, Bene Florin Gheorghe   +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, Jimon Ștefania, Boiță Marius   +2 more
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The correlation between double taxation conventions, tax compliance, and tax evasion. Empirical evidence from OECD countries

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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LEGAL REGULATION OF DOUBLE TAXATION AS A HIDDEN LEGAL ELEMENT IN RUSSIA: PROBLEMATICS AND TAX CONSEQUENCES

Russian Studies in Law and Politics
The relevance of the study lies in the authors consideration of the problem of hidden double taxation in the current tax legislation of the Russian Federation.
Regina E. Witzke, Kseniya D. Grezeva, Shamil R. Zaripov   +2 more
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Double Taxation Conventions in Central and Eastern European Countries

Journal of Legal Studies, 2016
In this article we provide a qualitative overview regarding the panacea of double taxation conventions in Central and Eastern European Countries. Double taxation paradigm highlights some serious problems arising from multiple taxation of the same income ...
Dumiter Florin, Jimon Ștefania
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Drumul spre Itaca sau unde este acasă în materie fiscală? / The road to Itacha or where is home in fiscal matters?

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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Theoretical and Practical Assessments of Transfer Prices. Legal Evidence from Romanian Case Law

Journal of Legal Studies, 2020
Transfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non ...
Dumiter Florin Cornel, Jimon Ștefania Amalia   +1 more
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Overriding the rules of international tax treaties by the means of the national law of one of the parties (“Tax treaty override”)

Правоприменение, 2023
Subject of research. The article is dedicated to the “tax treaty override”; it outlines debatable aspects, associated herewith. “Tax treaty override” is an action (in certain cases - omission of action) to expand taxation beyond (jurisdictional ...
I. A. Khavanova
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