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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
openaire +6 more sources
Tax treaty interpretation [PDF]
, 1994 PhDThis thesis analyses which principles should govern the interpretation of tax treaties. This field is complex - because tax treaties have a dual status.
Edwardes-Ker, Michael
core +4 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
doaj +1 more source
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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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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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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On the relevance of double tax treaties [PDF]
International Tax and Public Finance, 2018 AbstractThis 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. DTTs cannot be considered a bilateral issue, but must be viewed as a network.
Kunka Petkova +2 more
openaire +4 more sources
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
doaj +1 more source