The Network of Bilateral Tax Treaties of the Slovak Republic – Does It Mirror Challenges of the Globalization through Digitalization? A Cluster Analysis Approach [PDF]
Research background: Globalisations and movement of production factors - especially capital and workforces, call for elimination of double international juridical taxation and consequently for negotiation of bilateral tax treaties.
Kubicová Jana
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The (un)certain future of tax sparing credit in international tax treaty law [PDF]
Tax sparing clause emerged in double taxation treaties 63 years ago. Despite criticisms, it can presently be found in about 15% of all treaties, with Serbia having this clause in 46% of its double taxation agreements.
Popović Dejan, Ilić-Popov Gordana
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A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]
As international trade is expanding, international trade and tax disputes are increasing. Under international tax agreements, there are two mechanisms for the resolution of potential disputes between contracting States.
Alireza Salehifar
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Determining the Right Tax Jurisdiction in Bilateral Taxation Treaties and Preventing Abuse of the "Permanent Establishment" Concept [PDF]
Bilateral tax treaties in the world are significantly spreading as a tool for waiver of double taxation, which is an obstacle in the way of expansion of international trade.
Gholam Nabi Feyzi Chekab +1 more
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Arbitrability of International Tax Disputes [PDF]
Over the past years, "arbitration" as a means of settling international disputes has gained popularity, but compared to international tax disputes, the possibility of applying the arbitration clause is disputed. After the successful use of arbitration to
Naeem Noorbakhsh +2 more
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Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward [PDF]
This article analyzes the interaction between domestic tax legislation applied to avoid or combat a brain drain and the OECD and the UN model tax conventions, the two main models used by states in tax treaty negotiations.
Souza de Man Fernando
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The importance and effects of BEPS multilateral convention in international tax law [PDF]
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting is a result of the BEPS project carried out by the OECD and G20.
Popović Dejan, Ilić-Popov Gordana
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Taxation of capital gains of companies from the alienation of shares [PDF]
The paper deals with the tax treatment of capital gains on shares of companies both in national and tax treaty law. The authors indicate that the authentic interpretation of the Art.
Popović Dejan, Ilić-Popov Gordana
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Reservations and declarations to tax treaties
The subject of the article. The article represents a research of conceptual properties and issues of applying reservations and declarations to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit ...
I. A. Khavanova
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Analysis of anti-avoidance measures in the tax system of the post-Soviet countries
Purpose: of the article is to analyze anti-avoidance measures within the international tax policy and national tax systems of the countries of the post-Soviet space based on the provisions of the BEPS plan and other international events.Methods: the ...
I. A. Zhuravleva
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