Results 21 to 30 of about 55,447 (186)

The Multilateral Instrument: Avoidance of Permanent Establishment Status and the Reservations on behalf of Australia and the UK [PDF]

, 2013
This paper considers fully probabilistic system models. Each transition is quantified with a probability—its likelihood of occurrence. Properties are expressed as automata that either accept or reject system runs. The central question is to determine the
Ivanova, Milla
core   +3 more sources

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

InDret, 2012
Alberto Vega García, Ilja Rudyk
doaj   +3 more sources

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
doaj   +1 more source

Creation of service permanent establishment in Russian Federation when providing R&D services by foreign specialists

Правоприменение, 2021
The subject. The author examines the criteria of creation of service permanent establishment (PE) in Russia and possibility of creation of this type of PE in providing R&D services in Russia by foreign specialists.The aim of the paper is to confirm ...
E. A. Zakharov
doaj   +1 more source

Financial instruments in the OECD model tax convention [PDF]

, 2018
How are financial products taxed cross-border? This is subject of about 3,000 double tax treaties between states worldwide, most of which are based on the OECD's international standard template. Having grown over the last 100 years, this “OECD Model Tax Convention” is reaching its (interpretation) limits, in particular through the capital mobility and ...
openaire   +1 more source

Management control in the transfer pricing tax compliant multinational enterprise [PDF]

, 2008
This paper studies the impact of transfer pricing tax compliance on management control system (MCS) design and use within one multinational enterprise (MNE) which employed the same transfer prices for tax compliance and internal management purposes.
Cools, M., Emmanuel, C., Jorissen, A.
core   +1 more source

Tax Competition as a Challenge to the Governance of Global Economy [PDF]

, 2013
The paper analyses the role of tax competition in global economy. How can tax systems respond to the challenge - by international cooperation or by national rules, by tax harmonisation or by tax competition?
Kultalahti, Jukka, Penttilä, Seppo
core   +1 more source

International Double Taxation. Content, Consequences and Avoidance (I)

CECCAR Business Review, 2020
This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
doaj   +1 more source

Characteristic of mutual Agreement procedure in case of the double taxation treaty between Azerbaijan and Ukraine

Науковий вісник Ужгородського національного університету. Серія Право
The article is dedicated to comparative and legal analysis of the provisions on mutual agreement procedure in Art. 25 of the Convention between the Government of Ukraine and the Government of Azerbaijan Republic on Avoidance of Double taxation and ...
Parviz Arif Hasanov
doaj   +1 more source

International Double Taxation. Content, Consequences and Avoidance (II)

CECCAR Business Review, 2020
This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment.
Adriana CAZACU
doaj   +1 more source