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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Impact of double taxation treaties on cross-border acquisitions
Notas Económicas, 2019 In order to evaluate the impact of Double Taxation Treaties (DTTs) on the Foreign Direct Investment (FDI), we analysed the impact of a DTT implementation on both the number of cross-border acquisitions and the average value of M&A deals between companies
Catarina Pinto, Miguel Sousa
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Economics: Journal Articles, 2019 The paper evaluates the effect of Double Taxation Treaties (DTTs) on Spain’s inward and outward Foreign Direct Investment (FDI) for the period 1993–2013. Estimates produce positive and statistically significant coefficients.
Castillo-Murciego Ángela +1 more
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The (un)certain future of tax sparing credit in international tax treaty law [PDF]
Anali Pravnog Fakulteta u Beogradu, 2022 Tax sparing clause emerged in double taxation treaties 63 years ago. Despite criticisms, it can presently be found in about 15% of all treaties, with Serbia having this clause in 46% of its double taxation agreements.
Popović Dejan, Ilić-Popov Gordana
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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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Resolution of dual residence instances in the case of companies [PDF]
Anali Pravnog Fakulteta u Beogradu, 2020 The application of double taxation treaties presupposes that the potential cases of dual residence have been previously resolved. For this purpose, the major model-conventions on the basis of which double taxation treaties around the globe are negotiated
Živković Lidija
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The Network of Bilateral Tax Treaties of the Slovak Republic – Does It Mirror Challenges of the Globalization through Digitalization? A Cluster Analysis Approach [PDF]
SHS Web of Conferences, 2021 Research background: Globalisations and movement of production factors - especially capital and workforces, call for elimination of double international juridical taxation and consequently for negotiation of bilateral tax treaties.
Kubicová Jana
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Arbitrability of International Tax Disputes [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2017 Over the past years, "arbitration" as a means of settling international disputes has gained popularity, but compared to international tax disputes, the possibility of applying the arbitration clause is disputed. After the successful use of arbitration to
Naeem Noorbakhsh +2 more
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The Effect of Treaties on Foreign Direct Investment: Bilateral Investment Treaties, Double Taxation Treaties, and Investment Flows [PDF]
European Journal of International Law, 2009 exaly +2 more sources
Reservations and declarations to tax treaties
Правоприменение, 2021 The subject of the article. The article represents a research of conceptual properties and issues of applying reservations and declarations to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit ...
I. A. Khavanova
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