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Hybrid finance and double taxation treaties

Bulletin for International Taxation, 2009
Company finance is traditionally divided into equity and debt, but this does not truly capture the great diversity of the financial instruments available, and hybrid instruments incorporate elements of both equity and debt. From a tax perspective, the classification of hybrid instruments as equity or debt is crucial.
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Abolition of Double Taxation in the Treaty of Lisbon

Bulletin for International Taxation, 2010
Following the entry into force of the Treaty of Lisbon and the repeal of Art. 293 of the Treaty Establishing the European Community, must the Member States abolish international juridical double taxation between each other where not covered by secondary EU law directly under the founding treaties of the European Union?
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The Impact of Bilateral Investment Treaties and Double Taxation Treaties on Foreign Direct Investments

SSRN Electronic Journal, 2007
This is an empirical analysis upon the influence of investment agreements (multilateral and bilateral) and double taxation treaties (DTTs) upon foreign direct investment (FDI). A Gravity type and Knowledge-Capital type model is applied, to assess FDI flows from industrialized into developing countries.
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Exemption vs. Credit Method in International Double Taxation Treaties

International Tax and Public Finance, 2004
This paper examines the choice of international double taxation relief methods by two small countries that mutually exchange foreign direct investment. At the first stage, each country chooses between the exemption and the credit method (as prescribed by the OECD model treaty) and at the second stage, each country sets nationally optimal non ...
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The international treaties for the avoidance of double taxation of the republic of Uzbekistan

2019
In the article, the analyses of the issues relating to the tax rates of international treaties for the avoidance of double taxation in the Republic of Uzbekistan. In particular, proposals were made to eliminate the deficiencies in the determination of tax rates in international treaties between the states of Germany and the Russian Federation. Moreover,
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Trade, investment and size inequalities between countries and the asymmetry in double taxation agreements

Economic Modelling, 2023
Janusz Kudła   +2 more
exaly  

Methods for Elimination of Double Taxation under Double Tax Treaties – with Particular Reference to the Application of Double Tax Treaties in Sweden

2012
Kleist, D. 2012. Methods for Elimination of Double Taxation under Double Tax Treaties – with Particular Reference to the Application of Double Tax Treaties in Sweden. Iustus Förlag AB. Uppsala 2012. 372 pp. ISBN 978-91-7678-816-5. The study deals with the methods for elimination of double taxation that are applied in double tax treaties.
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