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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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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The Development of an Information Society and Electronic Commerce in the European Union in the Context of Selected Documents of the EU and International Organisations [PDF]
, 2012 In this article, the author presents selected documents on electronic commerce published by the United Nations Commission on International Trade Law, the World Trade Organization, the Organisation for Economic Cooperation and Development, the ...
M. Feltynowski, T. Czajkowski
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The hybrid financial instruments : the effects of the OECD BEPS Action 2 report and the ATAD [PDF]
, 2019 This contribution critically assesses the complex hybrid mismatch rule concerning financial instruments as developed under the OECD BEPS action 2-proposal and subsequently implemented in the Anti-Tax Avoidance Directive (ATAD).
Peeters, Bart, Vanneste, Lars
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The Political Economy of Bilateralism and Multilateralism: Institutional Choice in Trade and Taxation [PDF]
Trade relations are governed by the multilateral GATT, whereas the avoidance of international double taxation rests on a network of around 2000 bilateral treaties. Given the two regimes’ similar economic rationales this difference between bilateralism in
Rixen, Thomas, Rohlfing, Ingo
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Implementation of non-discrimination principle in legal enforcement of integration associations
Правоприменение, 2018 The subject. The problems of realization of non-discrimination principle in tax law of inte-gration associations are considered in the article.The purpose.
K. Ponomareva
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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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The electronic exchange of information and respect for private life, banking secrecy and the free internal market [PDF]
, 2010 The purpose of this essay is to assess the automatic exchange of information as described in EU Directive 2003/48 of 3 June 2003 on taxation of savings income in the form of interest payments with regard to the fundamental right of the individual to a ...
Baums, Theodor +2 more
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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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Information Sharing and International Taxation [PDF]
The sharing between national tax authorities of taxpayer-specific information has emerged over the last few years as a-probably "the"-central issue in the formation of international tax policy.Yet this refocusing of the debate on international taxation ...
Keen, M., Ligthart, J.E.
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