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, 2012 What exactly is tax treaty override ? When is it realized ? This thesis, which is the result of a co-directed PhD between the University of Bologna and Tilburg University, gives a deep insight into a topic that has not yet been analyzed in a systematic way. On the contrary, the analysis about tax treaty override is still at a preliminary stage.
De Pietro, C. +2 more
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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
doaj +1 more source
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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The importance and effects of BEPS multilateral convention in international tax law [PDF]
Zbornik Radova Pravnog Fakulteta u Nišu, 2017 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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Analysis of Factors Affecting Foreign Direct Investment (FDI) Inflows in Indonesia
Jurnal Analisis Bisnis Ekonomi, 2020 This study aims to examine the factors that influence the inflow of Foreign Direct Investment (FDI) in Indonesia. The data in this study are panel data that combines time series data and cross sectional data.
Agung Yuniarto
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(Un)constitutionality of the provision on the principal purpose of transaction or arrangement test from the tax treaties [PDF]
Anali Pravnog Fakulteta u Beogradu, 2019 The principal purpose of transaction or arrangement test (PPT) contained in MLI authorises tax authorities to deny a treaty benefit. The structure of PPT shows that tax authorities were given wide discretion.
Popović Dejan, Ilić-Popov Gordana
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Uluslararası Ekonomi, İşletme ve Politika Dergisi, 2021 A taxpayer has a different interpretation about compensation for capital loss in the USA with taxable income in Indonesia from the tax authority (DGT). This compensation is related to foreign income tax credit.
Muhammad Santoso
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Tax treaty override in Slovakia - Digital platform permanent establishment
Bratislava Law Review, 2018 The article analyses the new “digital platform permanent establishment” concept as a legal fiction establishing a fixed place even in situations where there is no actual fixed place.
Tomáš Cibuľa, Matej Kačaljak
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Tax Treaties and the Allocation of Taxing Rights With Developing Countries [PDF]
SSRN Electronic Journal, 2011 Worldwide income taxation in the country of residence is a legal dogma of international taxation. We question this dogma from the perspective of relations between developed and developing countries from a legal and economic perspective, and make a modern and fair proposal for tax treaties.
D. Paolini +3 more
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El Muhasaba: Jurnal Akuntansi, 2016 The purpose of this study is analizing value of international commerce before and after Indonesia - Qatar tax treaty committed. This research is quantitative rasearch and use real export and import value between Indonesia - Qatar for the periode 2004 ...
Andriansyah Andriansyah, Nurma Risa
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