Resolution of dual residence instances in the case of companies [PDF]
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]
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]
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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Costa Rica's Practice in its Treaties to avoid Double Taxation
Johnny Pacheco-Castro
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A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]
As international trade is expanding, international trade and tax disputes are increasing. Under international tax agreements, there are two mechanisms for the resolution of potential disputes between contracting States.
Alireza Salehifar
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The Concept of Beneficial Owner in Application of the Ukrainian Double Taxation Treaties [PDF]
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.
Selezen, Pavlo, Tymchenko, Leonid
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Reservations and declarations to tax treaties
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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The Role of Tax Treaties in Facilitating Development and Protecting the Tax Base [PDF]
The amount of taxes paid by multinational enterprises (MNEs) in host and home countries continues to make headline news. Corporate tax regimes, particularly those in many OECD countries, have never been more complex and the competition to attract and ...
Lang, Michael, Owens, Jeffrey
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A Note on Resolution of Tax Disputes Arising from DTTs and Implications for Developing Countries
Countries sign bilateral double tax treaties (DTTs) to avoid or mitigate double taxation in cross border economic activity. It is hardly possible to ignore the effect of double taxation in the era of globalization.
Aschalew Ashagre Byness
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