Results 21 to 30 of about 2,395,751 (384)

International Double Taxation. Content, Consequences and Avoidance (I)

CECCAR Business Review, 2020
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
doaj   +1 more source

Double Taxation Avoidance Agreement (Tax Treaty) Against International Transactions According to the Islamic Economic Perspective

Islamiconomic: Jurnal Ekonomi Islam, 2023
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
doaj   +1 more source

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.
doaj   +1 more source

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

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, Göritzer, Andreas, Pummerer, Erich   +2 more
core   +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
doaj   +1 more source

International Double Taxation Relief Provisions in India : A Critical Analysis

VISION: Journal of Indian Taxation, 2020
International double taxation of income has been a subject of frequent debate in courts in India and abroad. Double taxation of income arises essentially when two or more countries impose taxes on the same income of a taxpayer who happens to be a ...
Rabinarayan Samantara
semanticscholar   +1 more source

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
doaj   +1 more source

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
doaj   +1 more source

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
doaj   +1 more source