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A Critical Review of Mechanisms of Tax Information Exchange Agreements [PDF]

open access: yesپژوهش‌نامۀ انتقادی متون و برنامه‌های علوم انسانی, 2021
The principle of information flow, also known as the exchange of information, has been recognized in the field of international tax law and tools and mechanisms have been considered for its realization including the mechanisms of tax information exchange
Vahid Asadzadeh, Seyed Ghasem Zamani
doaj   +1 more source

Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward [PDF]

open access: yesAnali Pravnog Fakulteta u Beogradu, 2019
This article analyzes the interaction between domestic tax legislation applied to avoid or combat a brain drain and the OECD and the UN model tax conventions, the two main models used by states in tax treaty negotiations.
Souza de Man Fernando
doaj   +1 more source

A Positive Dialectic: Beps and The United States

open access: yesAJIL Unbound, 2020
This essay addresses the interaction between the changes in the international tax regime identified by Mason and U.S. international tax policy. Specifically, I will argue that contrary to the general view, the United States actively implemented the ...
Reuven S. Avi-Yonah
doaj   +1 more source

Taxpayers' confidentiality and privacy rights in the international exchange of tax information [PDF]

open access: yesZbornik Radova Pravnog Fakulteta u Nišu, 2014
The exchange of tax information is a distinctive feature of international tax cooperation processes. The trend of intensive communication between the national tax administrations has been a political priority in economically developed countries.
Anđelković Mileva
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Shifting Design Paradigms: Why Tomorrow's International Economic Law May Look More Like the Tax Regime than the WTO

open access: yesAJIL Unbound, 2020
Rampant unilateralism, insistence on national sovereignty, a wariness of multilateral institutions and third-party adjudication—for international trade lawyers, this is the stuff of nightmares.
Wolfgang Alschner
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Preface

open access: yesFinanse i Prawo Finansowe, 2022
The purpose of this paper which serves as an introduction to the special edition of the quarterly of “Finanse i Prawo finansowe. Journal of Finance and Financial Law” under the title of Current Challenges for National Tax Policies and International Tax ...
Maria Supera-Markowska
doaj   +1 more source

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

Towards an International Code for administrative cooperation in tax matter and international tax governance

open access: yesRevista Derecho del Estado, 2017
There is not a “Global Code” that encodes the duty of cooperation between tax authorities in the world, concerning the global tax system. This article addresses this issue by proposing a global Code of administrative cooperation in tax matters including ...
Eva Andrés Aucejo
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The Use of Contractual Arrangements by the U.S. International Tax Law to Distinguish between Royalties and Remuneration for Services

open access: yesМосковский журнал международного права, 2008
This article written by Artem Fokin (LL.M.), a New York tax attorney practicing in the area of international taxation, taxation of mergers and acquisitions, and taxation of derivatives, discusses the interplay between U.S. international tax law and other
A. V. Fokin
doaj   +1 more source

The (un)certain future of tax sparing credit in international tax treaty law [PDF]

open access: yesAnali 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
doaj   +1 more source

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