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Bulletin for International Taxation, 2021
The international tax architecture is dominated by thousands of bilateral treaties. However, multilateral tax treaties (MTTs) are also present in growing numbers. Recent developments have pointed the way to a possible future growth in MTTs. This article examines the advantages and disadvantages of MTTs, and considers their possible future role.
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The international tax architecture is dominated by thousands of bilateral treaties. However, multilateral tax treaties (MTTs) are also present in growing numbers. Recent developments have pointed the way to a possible future growth in MTTs. This article examines the advantages and disadvantages of MTTs, and considers their possible future role.
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SSRN Electronic Journal, 2017
This introductory section outlines the situation in Italy in relation to the legal standing of tax treaty law under the Italian constitutional system, and the treaty-making process. In the Italian constitutional system tax treaties are written conventions made by Italy with other sovereign States persons with international legal capacity, which contain
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This introductory section outlines the situation in Italy in relation to the legal standing of tax treaty law under the Italian constitutional system, and the treaty-making process. In the Italian constitutional system tax treaties are written conventions made by Italy with other sovereign States persons with international legal capacity, which contain
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Beneficial Ownership in Tax Law and Tax Treaties
2020This book explores the concept of beneficial ownership in equity law, the domestic tax laws of the United Kingdom, Canada and the United States, as well as its varied and increasing uses in international tax law. By analysing the evolution of beneficiary rights in equity and the use of beneficial ownership wording in tax law, the book draws a roadmap ...
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Expatriation Tax – Renouncing a Tax Treaty
SSRN Electronic Journal, 2012In this article, the author considers the implications of the various US expatriation tax regimes that have been enacted over the years, with special emphasis on renouncing a tax treaty. The author also suggests possible improvements to the current US expatriation regime.
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2011
The article examines the interrelation between European VAT and tax treaties.
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The article examines the interrelation between European VAT and tax treaties.
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2017
The prevailing view regarding tax treaties emphasizes their role as the indispensable mechanism for alleviating double taxation of international transactions. Policymakers assume that tax treaties benefit everyone involved. By reducing the burden of double taxation, the treaties facilitate the free movement of capital, goods and services, and help ...
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The prevailing view regarding tax treaties emphasizes their role as the indispensable mechanism for alleviating double taxation of international transactions. Policymakers assume that tax treaties benefit everyone involved. By reducing the burden of double taxation, the treaties facilitate the free movement of capital, goods and services, and help ...
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2019
This book takes a timely and detailed look at crucial areas concerning the entitlement to tax treaties.
Pistone P. +4 more
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This book takes a timely and detailed look at crucial areas concerning the entitlement to tax treaties.
Pistone P. +4 more
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2016
This chapter describes and explains how tax treaties operate in cross-border transactions. The situs of an international investment is often determined by the existence of a low tax, reducing a tax treaty in force. However, careful examination must be made as several countries have adopted anti-tax-treaty provisions to challenge treaty benefits to some
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This chapter describes and explains how tax treaties operate in cross-border transactions. The situs of an international investment is often determined by the existence of a low tax, reducing a tax treaty in force. However, careful examination must be made as several countries have adopted anti-tax-treaty provisions to challenge treaty benefits to some
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Tax Treaty Monitor: Tax Treaty News
Bulletin for International Taxation, 2009openaire +1 more source
2013
Diplomatic ties between China and Brazil officially started in 1974 with the establishment of diplomatic embassies in each country’s capital. In 2010, the second BRIC summit was held in Brazil and was attended by China’s President Hu. During the meeting, proposals were made for increased cooperation between Brazil and China on political and trade ...
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Diplomatic ties between China and Brazil officially started in 1974 with the establishment of diplomatic embassies in each country’s capital. In 2010, the second BRIC summit was held in Brazil and was attended by China’s President Hu. During the meeting, proposals were made for increased cooperation between Brazil and China on political and trade ...
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