Results 1 to 10 of about 55,447 (186)
Journal of Economic and Financial Sciences, 2017 Most tax treaties (including South Africa's) are based on the OECD Model Tax Convention on Income and Capital and the related Commentary (the 'OECD Model').
Lee-Ann Steenkamp
doaj +4 more sources
Practical Application of Art. 9 OECD Model Convention: the Czech Republic
Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2014 All transfer prices determined between the associated enterprises must comply with the arm’s length principle. The arm’s length principle for associated enterprises is mentioned in Art.
Veronika Solilová
doaj +3 more sources
Arbitration under the OECD Model Convention: Follow-up under Double Tax Conventions: An Evaluation
Intertax, 2014 On 18 July 2008, the OECD Council adopted amendments to the OECD Model Convention, by which inter alia the mutual agreement procedure of Article 25 was supplemented with an arbitration clause. This clause provides for a mandatory arbitration procedure if contracting states fail to reach a mutual agreement within a two-year period if the taxpayer ...
openaire +4 more sources
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
doaj +1 more source
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.
doaj +1 more source
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
doaj +1 more source
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
doaj +3 more sources
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
doaj +1 more source
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
doaj +1 more source
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
doaj +1 more source