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No. 07: Issues Related to Article 14 of the OECD Model Tax Convention
Issues in International Taxation, 2000openaire +3 more sources
The Impact of the UN and OECD Model Tax Conventions on Turkish Tax Treaties
Intertax, 2011Turkey is an appealing country for global investors. The economical importance of Turkey with the defragment of the geopolitical importance will gain deeper dimension and meaning. Since the outbreak of the global financial system crisis, the issue of tax cooperation between related parties has a priority on the international agenda.
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BUSINESSANDLAW, 2022
The current article aims to outline the role of the Commentary to the OECD Model Tax Convention on Income and on Capital as an interpretative tool in Bulgarian tax case law. Divergent approaches both from the Bulgarian National Revenue Agency and the Bulgarian Supreme Administrative Court constitute divergent practices that, in author’s opinion, may ...
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The current article aims to outline the role of the Commentary to the OECD Model Tax Convention on Income and on Capital as an interpretative tool in Bulgarian tax case law. Divergent approaches both from the Bulgarian National Revenue Agency and the Bulgarian Supreme Administrative Court constitute divergent practices that, in author’s opinion, may ...
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Article 26 of the OECD Model Tax Convention on Income and on Capital
2016This chapter explains Article 26 of the OECD Model Tax Convention on Income and on Capital. Canada has over ninety double tax conventions (DTCs) in force that contain an article modelled on Article 26, and the United States has over sixty. As explained in Chapter 6, both Canada and the United States generally reserve the use of DTCs for countries with ...
David S. Kerzner, David W. Chodikoff
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Article 3(2) of the OECD Model Tax Convention and the Scope of Domestic Law
Bulletin for International Taxation, 2012This article is the sixth of a series of articles that will feature the sessions to be presented at the 66th Congress of the International Fiscal Association (IFA), to be held in Boston September 30 through October 4. Readers who wish to register may do so at www.ifaboston2012.com or at the IFA USA Branch website www.ifausa.org (click on the IFA 2012 ...
A. Gunn, F. Engelen
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The United Nations Model and OECD Model Tax Conventions
2022Lorenzo Riccardi, Giorgio Riccardi
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The Dual System of OECD Model Tax Conventions from the Evolutionary Perspective
Intertax, 2018This article attempts to analyse, from the evolutionary perspective, the dual system of OECD Model Tax Conventions that arguably came into existence as a result of a tax policy choice that was introduced from the very beginning of works on bilateral model solutions concerning the elimination of international juridical double taxation.
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Tax Treatment of Team Performances under Art. 17 of the OECD Model Convention
World Tax Journal, 2010This article discusses the tax treatment of entertainment and sports team performances under Art. 17 of the OECD Model. A comprehensive description of tax implications of earning foreign income is provided for team members and teams. For the purposes of the analysis, team members have been divided into performing and non-performing employees, and ...
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SSRN Electronic Journal, 2011
This work aims at providing a comprehensive overview on the degree of consistency of the Conventions to avoid double taxation concluded by Italy (the “Treaties”) with the OECD Income and Capital Model Convention and the UN Income and Capital Model Convention (respectively the “OECD Model” and the “UN Model”, jointly referred to as the “Models”).
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This work aims at providing a comprehensive overview on the degree of consistency of the Conventions to avoid double taxation concluded by Italy (the “Treaties”) with the OECD Income and Capital Model Convention and the UN Income and Capital Model Convention (respectively the “OECD Model” and the “UN Model”, jointly referred to as the “Models”).
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Double Tax Treaties: Practical Problems in Article 8 of the OECD Model Convention
2014Article 8 of the OECD Model Convention is a special provision in the Model Convention. It prevails over the permanent establishment principle of Article 7 and deals with the taxation of profits from the operation of ships in international traffic.
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