Results 11 to 20 of about 303 (216)

A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]

Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2022
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
doaj   +1 more source

A Note on Resolution of Tax Disputes Arising from DTTs and Implications for Developing Countries

Mizan Law Review, 2019
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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Beneficial ownership of income as an antiabusive measure in Serbian Tax Law [PDF]

Zbornik Radova Pravnog Fakulteta u Nišu, 2020
The Serbian Corporate Income Tax Act contains a provision on the beneficial ownership of income (hereinafter: the BO provision), which is one of the conditions for the application of the preferential tax rate on income tax after tax deduction, which is ...
Vasović Miloš
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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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MEANING, EVOLUTION AND ROLE OF MUTUAL AGREEMENT PROCEDURE AS A TAX DISPUTE RESOLUTION MECHANISM

Міжнародні відносини: теоретико-практичні аспекти, 2018
The relevance of the study is determined by the fact that the issue of a tax dispute resolution is actual in the context of the globalization processes and global financial crisis state.
Pavlo Selezen
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Determining the Right Tax Jurisdiction in Bilateral Taxation Treaties and Preventing Abuse of the "Permanent Establishment" Concept [PDF]

Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2016
Bilateral tax treaties in the world are significantly spreading as a tool for waiver of double taxation, which is an obstacle in the way of expansion of international trade.
Gholam Nabi Feyzi Chekab, Naeem Noorbakhsh   +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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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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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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Multilateral Convention (MLI) – Tax Evolution or Revolution?

Studia Iuridica Lublinensia, 2018
The Multilateral Convention (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) is an international agreement, which was signed on 7 June 2017 in Paris.
Agnieszka Franczak
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