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On the development of Russian tax treaty case law
The research subject. This study focuses on recent developments (2021-2023) in Russian tax treaty case law.The purpose of the research. The objective of this research is to analyze the key trends and developments in tax treaty case law in Russia for the ...
E. V. Kilinkarova
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Pharma Sector under the Influence of the Parafiscal Mechanism: Clawback Tax [PDF]
The authors of this paper address the issue of the „Clawback Tax” in the context of the desire to ensure an efficient and sustainable public health care system, but without affecting the legitimate interests of the Romanian Pharma Sector.
Nicoleta Asalos +2 more
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Taxation of Digital Services in the Context of Freedom to Provide Services
The presented paper is dedicated to the taxation of digital services in the light of one of the basic freedoms of the European internal market, namely the freedom to provide services according to Art.
Soňa Simić
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The history of double tax conventions in Croatia
After a short introduction, the authors briefly describe the national experience in handling the problems of international double taxation through double tax conventions.
Hrvoje Arbutina +1 more
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Holding a Double Taxation Avoidance Agreement (P3B) or a Tax treaty is to avoid double taxation. The presence or absence of this tax treaty greatly affects investors’ profits in international trade transactions.
Firqotus Sa'idah, Tulus Suryanto
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Tax Arbitration Through Offshore Centres аnd Tax Havens [PDF]
The aim of the study is to capture the most relevant aspects regarding the functioning of offshore centres and tax havens, focusing in particular on the most important conceptual and instrumental clarifications.
A. S. Dirva, C. Dirva
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Security and political aspects of dirty money [PDF]
When the UN General Assembly, thirty years ago, directed their Commission on Narcotic Drugs to prepare an international treaty, with the aim to curb, through legal regulations, the international narcotic drugs trade and the resulting dirty money, no one ...
Wyss Ralph
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Measuring Tax Treaty Negotiation Outcomes: The Actionaid Tax Treaties Dataset [PDF]
capital gains tax; corporation tax; double taxation agreement; foreign direct investment; sub-Saharan Africa; Asia; tax treaty; withholding tax.
openaire +1 more source
Layered tax governance of multinational debt: regulatory interaction under BEPS, ATAD and Pillar Two
Cross-border intra-group debt is governed by several legal regimes that may apply concurrently to the same payment. Transfer-pricing rules, anti-hybrid provisions, earnings-stripping limits, treaty-abuse tests and the Pillar Two minimum tax were ...
Siamand Hesami +1 more
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Most tax treaties (including South Africa's) are based on the OECD Model Tax Convention on Income and Capital and the related Commentary (the 'OECD Model').
Lee-Ann Steenkamp
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