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The Potential of Multilateral Tax Treaties 1. The rich literature

ing and possibly harmonizing international tax regimes. In section 3., the paper turns to explore in some detail the potential advantages to using tax treaties as a form of multilateral solution. In section 4., the paper evalu- ates the CARICOM multilateral double taxation treaty to see if in practice that treaty delivers on the ...


Issues in International Taxation and the Role of the IMF; IMF Policy

Jun 28, 2013 ... related points provide that tax collectors should be able to see easily through to companies' owners (point 3) and ... ISSUES IN INTERNATIONAL TAXATION AND THE IMF. 4. INTERNATIONAL MONETARY FUND level of taxation below that which would be chosen if countries took full account of how each ...


OECD work on taxation

Sep 5, 2016 ... 3. Preface by the OECD Secretary-General. 4. Introduction by Pascal Saint- Amans. 6. OECD and the G20. 9. Reforming international tax rules - BEPS ... We also look at issues that directly affect everyone's daily life, like how much people pay in taxes and social security, ..... implementing tax treaty-related.


Committee of Experts on International Cooperation in Tax Matters

Oct 13, 2015 ... scientific equipment” and software-payment related issues. Discussion ... equipment-related issues, Differences between article 12 of the United Nations Model Double Taxation Convention .... Vann, Jiménez and Brooks, supra note 4; E.B. Nortcliffe (Canadian Tax Foundation International Tax Conference,.


Taxation and Technology transfer: Key Issues

The studies in the series address key policy issues and draw lessons from successful experiences with ... Chapter I The application of international tax principles to technology transfer ........7. 1. ..... income tax. 2 See the United Nations Model Double Taxation Convention between Developed and Developing Countries.



4 See David L. Forst, The Continuing Vitality of Source-Based Taxation in the Electronic. Age, 15 TAX NOTES INT'L ... This article endeavors to defend the thesis that the developed countries' re- fusal to change the ... 6 For detailed review of the history of international tax treaties, see Michael J. Graetz &. Michael M. O'Hear, ...


Rethinking Treaty Shopping: Lessons for the European Union

For a description of various treaty-shopping arrangements, see OECD Conduit. Companies Report in OECD, Committee on Fiscal Affairs of the OECD, International. Tax Avoidance and Evasion, Four Related Studies, Double Taxation Conventions and the. Use of Conduit Companies, Issues in International Taxation Series, ...


Double Tax Treaties and Their Interpretation

This Article explores the problems and significant issues which arise when interpreting double tax treaties. Using the various model taxation trea- ties' and in particular an official commentary published by the Organization t. Professor of Law and Director of the Research Unit for Foreign and International. Financial and Tax ...


Interpreting the Concept of “Beneficial Ownership”

This thesis assumes that the prevention of tax avoidance (or of double non- taxation) is probably a purpose of tax treaties based on the OECD Model. Since the rise of recent phenomena such as international tax evasion, tax planning, and money laundering (problems that prompted the OECD to issue a series of reports on ...


International Taxation in the Digital Economy: Challenge Accepted

in international taxation, this review reveals that the understanding of the digital economy and .... 11. 3.1.1. Treaty Abuse and the Avoidance of the PE Status . ... 4 . A Deeper Look at Digital Business Models, Value Creation and Tax Consequences........... 22. 4.1. Case Studies on Value Creation of Digital Business Models .


Can the OECD Mend the International Tax System?

Sep 16, 2013 ... opment, where he is coordinating a research group on unitary taxation with special reference to devel- oping countries. He is the ... In principle, changes to the model treaty, for example to include tiebreaker rules, ... Tax Avoidance and Evasion: Four Related Studies, Issues in Interna- tional Taxation No.


Tax Treaties and Foreign Direct Investment: Potential versus

November 2004 , Volume 11, Issue 6, pp 775–802 ... Bilateral tax treaties are an important method of international tax cooperation. I survey the existing literature on these agreements, highlighting the differences between the standard view that treaties increase foreign direct investment and the empirical evidence that finds ...


At the intersection of international - Unraveling tax issues in the

4. 3. 11. 12. 13. 2 | Content first published in Global Tax Weekly 16 April 2015. These local country and international dynamics present fundamental considerations for tax ... research and development (R&D) and other technology- related issues to their business models from the very outset, as they .... model tax conventions.



Sep 13, 2007 ... international tax literature is increasingly using terms such as hard law, customary law, and soft ... Commentaries to the OECD Model Convention: Ubiquitous, Often Controversial; but Could. They Possibly Be ... Another OECD- related example is currently at issue in a recent dialogue among international tax  ...


Chapter 2 Fundamental principles of taxation

evaluation of the taxation issues related to e-commerce. Although most of the new business models identified in Chapter 4 did not exist yet at the time, these principles, with ..... four economists. Instead, supported by the development of the OECD and. UN Model treaties, the international tax framework developed around a.


International Taxation and Tax Rulings: Policy issues at Challenging

May 8, 2016 ... http://www.europarl.europa.eu/studies ... International Taxation and Tax Rulings: Policy Issues at Challenging Times. PE 578.987. 3. CONTENTS. INTRODUCTION. 4. 1. ARE WE MOVING IN THE RIGHT DIRECTION? .... OECD Model Tax Convention as proposed in the BEPS Final Report for Action 7). 2.2.


Indeterminacy, Complexity, Technocracy and the Reform of

Corporate Taxation. Sol Picciotto. Lancaster University Law School, UK. Abstract. Recent public concerns and publicity about the extent of tax avoidance by some of the ... International tax coordination is governed by tax treaties, expressed in rules which must ..... citly accepted in Article 7(4) of the model tax treaty. Although  ...


International Taxation of E-Commerce: Persistent Problems and

Oct 24, 2008 ... http://go.warwick.ac.uk/jilt/2008_1/basu. 4. The basic question is how e- commerce interacts with traditional principles of taxation. While some authors ... Concerns have been expressed that e-commerce could result in the erosion of tax bases. Consumption taxes are levied on the principle of taxation at.


(permanent establishment) of the oecd model tax convention

Oct 12, 2011 ... Despite the long history of the concept of permanent establishment, its practical application raises a number of issues. The Committee on Fiscal Affairs, through a subgroup of its Working Party 1 on Tax. Conventions and Related Questions, has examined various questions related to the interpretation and.


Principles, Policy and Practice

Apr 1, 2017 ... UvA/IBFD. Advanced Master's in International Tax Law: Principles, Policy and Practice ... 27 Transparency, information and collection of taxes. 28 Moot court. 28 LLM Thesis. 29 Additional classes. 31 The Participating Institutions. 31 University of Amsterdam .... law, including domestic law, model tax treaties,.