Practical Application of Art. 9 OECD Model Convention: the Czech Republic
Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2014 All transfer prices determined between the associated enterprises must comply with the arm’s length principle. The arm’s length principle for associated enterprises is mentioned in Art.
Veronika Solilová
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Users, Data, Networks A Proposal for Taxing the Digital Economy in the European Single Market. Bertelsmann Stiftung Policy Paper 12 March 2019 [PDF]
, 2019 Fair taxation of digital businesses will be a key issue in the forthcoming European election campaign. The debate will most likely revolve around the introduction of a new “digital tax” on companies’ turnover, as proposed by the European Commission, for ...
Dittrich, Paul-Jasper +1 more
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Tax discrimination in EU Law and the OECD model tax convention
, 2021 The use of taxes by states as a tool to protect their nationals and domestic products constitutes a problem, tax discrimination, to be avoided in the international arena. Tax discrimination creates a heavy tax burden on foreign goods, services and persons as an obstacle to international trade. Increased mobility as a result of globalization caused high
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International Taxation in an Era of Digital Disruption: Analyzing the Current Debate [PDF]
, 2018 The “taxation of the digital economy” is currently at the top of the global international tax policymaking agenda. A core claim some European governments are advancing is that user data or user participation in the digital economy justifies a gross tax ...
Grinberg, Itai
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Requirements for assuming a permanent establishment under Art. 5 OECD Model Tax Convention
SCENTIA International Economic Review, 2021 In January 2019, the German Federal Finance Court defined the legally binding requirements with respect to a fixed place of business being a matter of a permanent establishment according to German law, thus the revenue generated being subject to the German taxation.This article addresses the research question ‘Which criteria have to be met by a ...
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Analisis Penerapan Arm's Length Principle Atas Transfer Pricing melalui Proses Comparability Analysis (Studi Kasus PT XYZ Tahun 2012) [PDF]
, 2015 The growth of the company into a multinational company that automatically transactions carried out more and more and complex, the company will look for a way to efficiency in spending. One of the ways used to efficiency is to make transfer pricing.
Adiat, S. (Subkhan)
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Globalization and the Precarious State of Public Finance in Nigeria [PDF]
, 2012 As globalization eviscerates national borders, governments in both developed and developing countries are discovering that their tax base is eroding, especially their ability to tax the proceeds and profits from corporate investment and finance ...
ADEGBIE, F. F., Fakile , A. S.
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Thin Capitalisation Safe Harbour Rules: A Proposed Conceptual Legislative Design
Potchefstroom Electronic Law JournalCurrent legislation in respect of thin capitalisation is viewed as unclear and complex, which has resulted in both the Davis Tax Committee and National Treasury commenting that thin capitalisation safe harbour rules should be investigated for ...
Lize Goosen, Cecileen Greeff
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Bilateral tax treaties: is sufficient relief provided in triangular tax situations? [PDF]
, 2014 Thesis (M.Com. (Taxation))--University of the Witwatersrand, Faculty of Commerce, Law and Management, School of Accountancy, 2014.With the international platform for cross border investment and economic development growing year on year at a steady pace ...
Uys, Odette
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Critical Assessment of the Tie-breaker Rule Using the Example of the DTT Germany-Poland
Prace Naukowe Uniwersytetu Ekonomicznego we Wrocławiu, 2019 Taxpayers establishing their economic and personal interests in more than one country run the risk of becoming a tax resident in more than one tax jurisdiction.
Magdalena Janiszewska +2 more
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