Results 11 to 20 of about 204,046 (312)
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
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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
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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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Beneficial ownership of income as an antiabusive measure in Serbian Tax Law [PDF]
Zbornik Radova Pravnog Fakulteta u Nišu, 2020 The Serbian Corporate Income Tax Act contains a provision on the beneficial ownership of income (hereinafter: the BO provision), which is one of the conditions for the application of the preferential tax rate on income tax after tax deduction, which is ...
Vasović Miloš
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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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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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International Journal of Business, Economics, and Social Development, 2022 Tax Treaty is a bilateral(two-party) agreement made by two or more than two countries to resolve some issues involving double taxation, transfer pricing, and treaty shopping.
Tivana Arbiani Candini +3 more
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