Results 1 to 10 of about 204,664 (312)
On the relevance of double tax treaties [PDF]
International Tax and Public Finance, 2020 This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping.
Petkova, Kunka +2 more
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Optimized profit repatriation in multinational enterprises through cross-border change of legal form and international tax management [PDF]
Heliyon, 2023 This article shows for the first time that the cross-border change of legal form can be used for tax-optimized profit repatriation. By means of a cross-border change of legal form of the foreign EU corporation prior to distribution into another foreign ...
Thomas Kollruss
doaj +2 more sources
Towards a harmonised eac tax sysyem: curent status, challenges and way forward [PDF]
სამართალი და მსოფლიო, 2023 Under Article 79 of the EAC Treaty, the Partner States have under- taken to harmonize and rationalize investment incentives to promote the Community as a single investment area while avoiding double taxation. Article 83 of the same Treaty states that the
Pie Habimana
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Правоприменение, 2023 Subject of research. The article is dedicated to the “tax treaty override”; it outlines debatable aspects, associated herewith. “Tax treaty override” is an action (in certain cases - omission of action) to expand taxation beyond (jurisdictional ...
I. A. Khavanova
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Navigating optimal treaty-shopping routes using a multiplex network model.
PLoS ONE, 2021 The international tax treaty system is a highly integrated and complex network. In this system, many multinational enterprises (MNEs) explore ways of reducing taxes by choosing optimal detour routes.
Sung Jae Park, Kyu-Min Lee, Jae-Suk Yang
doaj +1 more source
Acta Universitatis Carolinae Iuridica, 2022 This article deals with whether the most recent version of the OECD Commentary should be used when interpreting a double taxation convention or the version that was in force at the time the tax treaty was concluded.
Wojciech Morawski
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Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward [PDF]
Anali Pravnog Fakulteta u Beogradu, 2019 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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IBLAM Law Review, 2021 The Indonesia-Netherlands Tax Treaty is widely used by multinational corporations to avoid tax. The most crucial matter is how to determine the beneficial owner status, which is one of the requirements in the use of the Tax Treaty between Indonesia and ...
Ardianyah Ardianyah
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Taxpayer protection standard in international tax disputes
Правоприменение, 2022 The research project aims to find the most optimal solution to develop the current level of taxpayers' guarantees in the tax treaty disputes resolution procedures.The subject of the article is the analysis of the case law of the European Court of Human ...
M. D. Polenchuk
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The (un)certain future of tax sparing credit in international tax treaty law [PDF]
Anali Pravnog Fakulteta u Beogradu, 2022 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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