Results 201 to 210 of about 604 (239)
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The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties
2012This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions
Burgers, I.J.J. +2 more
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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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The United Nations Model and OECD Model Tax Conventions
2022Lorenzo Riccardi, Giorgio Riccardi
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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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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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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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The Taxation of Capital Income in the Light of the Provisions of the OECD Model Tax Convention
2020Vergilendirilebilir gelir unsurlarındanbiri de menkul sermaye iratlarıdır. Üretimisürecine dâhil olmaksızın, nakdi veya nakdenbelirlenebilen değer üzerinden yatırım ileelde edilen gelir, menkul sermaye iradı olarakaçıklanabilmektedir. Bu çerçevede 193 sayılıGelir Vergisi Kanunu’nda da alacak-borçilişkisinden kaynaklanan faiz alacağı, ortaklıkhakkı ...
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