Results 251 to 260 of about 204,664 (312)

Tax Treaties and the Mobility of Workers

European Business Law Review, 2022
After 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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Multilateral Tax Treaties

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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Tax Treaty Disputes in Italy

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
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Beneficial Ownership in Tax Law and Tax Treaties

2020
This 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, 2012
In 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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European VAT and Tax Treaties

2011
The article examines the interrelation between European VAT and tax treaties.
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The Tax Treaties Myth1

2017
The prevailing view regarding tax treaties emphasizes their role as the indispensable mechanism for alleviating double taxation of international transactions. Policymakers assume that tax treaties benefit everyone involved. By reducing the burden of double taxation, the treaties facilitate the free movement of capital, goods and services, and help ...
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Tax Treaty Entitlement

2019
This book takes a timely and detailed look at crucial areas concerning the entitlement to tax treaties.
Pistone P., Lang M., Rust A., Schuch J., Staringer C.   +4 more
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The International Tax Treaty

2016
This chapter describes and explains how tax treaties operate in cross-border transactions. The situs of an international investment is often determined by the existence of a low tax, reducing a tax treaty in force. However, careful examination must be made as several countries have adopted anti-tax-treaty provisions to challenge treaty benefits to some
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