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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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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 Concept of Beneficial Owner in Application of the Ukrainian Double Taxation Treaties [PDF]
Juridica International, 2016 The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of application of the provisions of double-taxation treaties since the adoption of the Tax Code of Ukraine, in 2010. The changing nature of the concept of beneficial owner, its importance as an instrument for counteraction of treaty shopping, and the ...
Leonid Tymchenko, Pavlo Selezen
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Scope Of International Treaties To Avoid Double Taxation
Competitiveness and Innovation in the Knowledge Economy, 2023The conventions concluded by the Republic of Moldova on the notion of "person" do not include the element of society, replacing it with the notion of a legal entity. Data: However, the conventions concluded by the Republic of Moldova in the article that will refer to the general definitions (art. 3), will not even refer to the content of a legal person,
exaly +4 more sources
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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