Results 11 to 20 of about 42,963 (273)

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

open access: yesFaṣlnāmah-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

The Role of Tax Treaties in Facilitating Development and Protecting the Tax Base [PDF]

open access: yes, 2014
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
core   +1 more source

Reservations and declarations to tax treaties

open access: yesПравоприменение, 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
doaj   +1 more source

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

open access: yesMizan 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
doaj   +1 more source

Beneficial ownership of income as an antiabusive measure in Serbian Tax Law [PDF]

open access: yesZbornik 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
doaj   +1 more source

The relationship between Double Taxation Agreements and the provisions of the South African Income Tax Act

open access: yesJournal 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

MEANING, EVOLUTION AND ROLE OF MUTUAL AGREEMENT PROCEDURE AS A TAX DISPUTE RESOLUTION MECHANISM

open access: yesМіжнародні 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
doaj   +1 more source

Determining the Right Tax Jurisdiction in Bilateral Taxation Treaties and Preventing Abuse of the "Permanent Establishment" Concept [PDF]

open access: yesFaṣlnāmah-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   +1 more
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”)

open access: yesПравоприменение, 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

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