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SSRN Electronic Journal, 2017 This introductory section outlines the situation in Italy in relation to the legal standing of tax treaty law under the Italian constitutional system, and the treaty-making process. In the Italian constitutional system tax treaties are written conventions made by Italy with other sovereign States persons with international legal capacity, which contain
Garbarino, Carlo, Carlo Garbarino
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Tax Treaties and the Mobility of Workers
European Business Law Review, 2022After an introduction about the mobility of workers under the Covid crisis and its tax implications (section 1), the article begins by providing at section 2 a general overview of Art. 15 § 1 which attributes taxing power to the country where the activities are carried out as well as to the country of residence of the worker, creating a potential ...
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Beneficial Ownership in Tax Law and Tax Treaties
2020This book explores the concept of beneficial ownership in equity law, the domestic tax laws of the United Kingdom, Canada and the United States, as well as its varied and increasing uses in international tax law. By analysing the evolution of beneficiary rights in equity and the use of beneficial ownership wording in tax law, the book draws a roadmap ...
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Expatriation Tax – Renouncing a Tax Treaty
SSRN Electronic Journal, 2012In this article, the author considers the implications of the various US expatriation tax regimes that have been enacted over the years, with special emphasis on renouncing a tax treaty. The author also suggests possible improvements to the current US expatriation regime.
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Qualifikation of the Digital Services Tax Under Tax Treaties
Intertax, 2019peer ...
Hohenwarter, Daniela +3 more
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Bulletin for International Taxation, 2021
The international tax architecture is dominated by thousands of bilateral treaties. However, multilateral tax treaties (MTTs) are also present in growing numbers. Recent developments have pointed the way to a possible future growth in MTTs. This article examines the advantages and disadvantages of MTTs, and considers their possible future role.
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The international tax architecture is dominated by thousands of bilateral treaties. However, multilateral tax treaties (MTTs) are also present in growing numbers. Recent developments have pointed the way to a possible future growth in MTTs. This article examines the advantages and disadvantages of MTTs, and considers their possible future role.
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2011
The article examines the interrelation between European VAT and tax treaties.
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The article examines the interrelation between European VAT and tax treaties.
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Bulletin for International Taxation, 2009
The author, in this “Tax Treaty News”, considers various recent Belgian, Canadian and US treaty cases of note, as well as commenting on the October 2010 meeting of the UN Committee of Experts on International Cooperation in Tax Matters regarding the anticipated 2011 UN Model Tax Convention.
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The author, in this “Tax Treaty News”, considers various recent Belgian, Canadian and US treaty cases of note, as well as commenting on the October 2010 meeting of the UN Committee of Experts on International Cooperation in Tax Matters regarding the anticipated 2011 UN Model Tax Convention.
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