Results 11 to 20 of about 604 (239)

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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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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Review of the Russian Law Enforcement Practice with Respect to the Interpretation of the OECD Model Tax Convention

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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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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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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UN MTC Article 26: Inequitable Exchange of Information Regime—Questionable Efficacy in Asymmetrical Bilateral Settings

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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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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Explaining Reservations to the OECD Model Tax Convention: An Empirical Approach

InDret, 2012
Alberto Vega García, Ilja Rudyk
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Analysis Method of Transfer Pricing Used by Multinational Companies Related to Tax Avoidance and its Consistencies to the Arm's Length Principle

Binus Business Review, 2015
The purpose of this study is to evaluate about how Starbucks Corporation uses transfer pricing to minimize the tax bill. In addition, the study also will evaluate how Indonesia’s domestic rules can overcome the case if Starbucks UK case happens in ...
Nuraini Sari, Ririn Susanti Hunar
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