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Reservations and declarations to tax treaties
Правоприменение, 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
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Nationality non-discrimination in Serbian tax treaty law [PDF]
Anali Pravnog Fakulteta u Beogradu, 2014 This paper deals with the nationality non-discrimination provision in Serbian double taxation treaties. First the author analyses the historical development of the nationality non-discrimination clause found the in the OECD Model Tax Convention and ...
Kostić Svetislav V.
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International Journal of Business, Economics, and Social Development, 2022 Tax Treaty is a bilateral(two-party) agreement made by two or more than two countries to resolve some issues involving double taxation, transfer pricing, and treaty shopping.
Tivana Arbiani Candini +3 more
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Exchange of Information in Tax Matters
Journal of Education, Health and Sport, 2017 The main aim of this paper is to present issues related to exchange of tax information. The author focuses on models of exchange of information and boundaries of obligations in reference to above-mentioned problems.
Paweł Szwajdler
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Arbitrability of International Tax Disputes [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2017 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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Brain drain and tax competition: Do we need another BEPS? [PDF]
Anali Pravnog Fakulteta u Beogradu, 2019 In the article we argue that the origins of the international tax base erosion in the corporate sector, which are the harmful tax competition for capital and old-fashioned international tax rules, are also relevant for the taxation of income of the high ...
Milogolov Nikolai, Berberov Azamat
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Application of the MLI Convention as a means of ensuring the constitutional obligation to pay taxes
Конституційно-правові академічні студії, 2023 The purpose of the article is to determine the consequences of the application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument (MLI) in Ukraine, to evaluate it ...
Yaroslav Hretsa
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The Multilateral Instrument: Avoidance of Permanent Establishment Status and the Reservations on behalf of Australia and the UK [PDF]
, 2013 This paper considers fully probabilistic system models. Each transition is quantified with a probability—its likelihood of occurrence. Properties are expressed as automata that either accept or reject system runs. The central question is to determine the
Ivanova, Milla
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The real estate clause in the OECD model tax convention and its reception into Polish law
Financial Law Review, 2023 This article deals with the issue of the real estate clause and its reception to Polish law as a real estate company. The research was conducted on the grounds of Corporate Income Tax Act and Personal
Piotr Gajewski
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Московский журнал международного права, 2016 This article focuses on the analysis of practical application of the OECD Model Tax Convention on Income and on Capital, and Commentaries to it by the Russian public authorities.
Maria S. Pekarskaya
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