Results 11 to 20 of about 55,447 (186)
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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Tax and legal treatment of hybrid financial instruments [PDF]
Anali Pravnog Fakulteta u Beogradu, 2018 Besides the motives not prevailingly concerning the tax, hybrid financial instruments are used both in the context of one tax system, and particularly in the international scenario, aiming at tax savings generation.
Bosankić Dragan
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The quality of legal language of tax law: Something worth noting
Prawo Budżetowe Państwa i Samorządu, 2023 The article is devoted to the problem of legal language and the various distortions that occur in the processes of using it. The author analyzes the most obvious mistakes that users of this language make and diagnoses the reasons for their occurrence ...
Bogumił Brzeziński
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Beneficial ownership of income as an antiabusive measure in Serbian Tax Law [PDF]
Zbornik Radova Pravnog Fakulteta u Nišu, 2020 The Serbian Corporate Income Tax Act contains a provision on the beneficial ownership of income (hereinafter: the BO provision), which is one of the conditions for the application of the preferential tax rate on income tax after tax deduction, which is ...
Vasović Miloš
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Arbitration in international tax law: Legal obstacles to agreeing [PDF]
Anali Pravnog Fakulteta u Beogradu, 2018 Article 25 (5) of the OECD Model Convention contains a provision that defines the failure of the mutual agreement procedure to solve a dispute whether a person has been taxed in a manner that is not in accordance with the provisions of the Convention ...
Popović Dejan, Ilić-Popov Gordana
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Laws, 2022 The United Nations Model Tax Convention between Developed and Developing Countries (UN MTC) Article 26 charts out an exchange of information (EOI) regime “between developed and developing countries”, feigning that it is more favorable to the latter set ...
Muhammad Ashfaq Ahmed
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Beneficial ownership provisions in tax treaties between developed and developing countries: the Canada/South Africa example [PDF]
, 2013 In the years since the Organisation for Economic Cooperation and Development (OECD) adopted its first draft tax treaty in 1963, the world has experienced an astonishing surge in international trade and investment.
Steenkamp, Lee-Ann
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Controlled Foreign Corporation and Importance of Exchange of International Information
International Journal of Public Finance, 2020 Countries that want to take a share from the funds and capital flows of the saving countries and companies have started to make tax arrangements in order to get a share from the market in question with their unfair competition.
Taner Ercan
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Taxpayer protection standard in international tax disputes
Правоприменение, 2022 The research project aims to find the most optimal solution to develop the current level of taxpayers' guarantees in the tax treaty disputes resolution procedures.The subject of the article is the analysis of the case law of the European Court of Human ...
M. D. Polenchuk
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