Certainty and Uncertainty in Tax Law: Do Opposites Attract? [PDF]
The principle of certainty of taxation is the dimension of a general requirement of certainty in the legal system. The purpose of this article is to argue the thesis that uncertainty in tax law is not always an absolute evil, sometimes it acts as a means of the most optimal (and in some cases the only possible) settlement of relations in the field of ...
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The effects of modern technology on legal certainty in tax law: The new frontier
The speedy reforms of Serbia's tax legislation, often introduced on the basis of comparative sources, has created a significant body of dormant legislation, due to the lack of knowledge and experience to implement them. The article explores some aspects of legitimacy of Serbian tax legislation, namely the consequences of the misalignment of tax law ...
Svetislav Kostic, Jelena Jerinić
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Neutrality and legal certainty in tax law and the effective protection of taxpayers’ rights [PDF]
Taxation and tax law cannot exist without biases because tax law can be seen per definition as a set of biases. Even if the state pursuing its fiscal policy cannot be neutral, one can expect to enforce the principle of equal treatment before the law. Besides, state intervention need be in proportion to the objectives of the policy of redistribution or ...
Daniel deák
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The Reasonableness Test of the Principal Purpose Test Rule in OECD BEPS Action 6 (Tax Treaty Abuse) versus the EU Principle of Legal Certainty and the EU Abuse of Law Case Law [PDF]
The Reasonableness Test of the Principal Purpose Test Rule in OECD BEPS Action 6 (Tax Treaty Abuse) versus the EU Principle of Legal Certainty and the EU Abuse of Law Case Law The OECD BEPS Action 6 report contains a principal purpose test rule (PPT rule) for the purpose of combating abuse of tax treaties.
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Reorientation of Tax Legal Certainty in Indonesia: An Exploration of Transcendental Law [PDF]
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Tax Law Certainty on The Sale of Food and Beverages after The Enactment of Law Number 1 of 2022
Taxes on Certain Goods and Services (TCGS) is a concept of integrating consumption-based taxes contained in Law Number 1 of 2022 concerning Financial Relations between the Central Government and Regional Governments. The provisions for tax collection in this new law also change local taxation policies, particularly on tax collection on the sale of food
Josep Irvan Gilang Hutagalung +2 more
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Legislating unorthodox taxes: The Hungarian experience [PDF]
To date, a series of non-traditional schemes have proliferated in the area of tax law, challenging the widely accepted principles of tax legislation.
Deák, Dániel
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Predicting the ‘Unpredictable’ General Anti-Avoidance Rule (GAAR) in EU Tax Law [PDF]
General Anti-Avoidance Rule (GAAR) is a type of rule designed to combat the tax-avoidance scenarios that in a legal form lawfully but aims to circumvent the legal consequences.
Chen, S.-C. (Shu-Chien)
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Cross-border Intra-group Hybrid Finance and International Taxation [PDF]
In intra-group finance hybrid instruments allow for tailor-made form of finance. Hence hybrid finance is often used for international tax planning in multinational groups. Due to a lack of international tax harmonization or tax coordination qualification
Eberhartinger, Eva +2 more
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Business splitting: compliance with the principle of tax certainty in law enforcement practice
The subject. The problems of business splitting, when several new business entities are created on the basis of an existing organization in order to maintain a preferential special tax regime, are considered in the article. The aim of this paper is to find out criteria of unjustified tax benefit in the cases concerning business splitting.
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