Log in

Relevant bibliographies by topics / International Tax Law / Journal articles

To see the other types of publications on this topic, follow the link: International Tax Law.

Journal articles on the topic 'International Tax Law'

Author: Grafiati

Published: 4 June 2021

Last updated: 25 July 2025

Create a spot-on reference in APA, MLA, Chicago, Harvard, and other styles

Select a source type:

Consult the top 50 journal articles for your research on the topic 'International Tax Law.'

Next to every source in the list of references, there is an 'Add to bibliography' button. Press on it, and we will generate automatically the bibliographic reference to the chosen work in the citation style you need: APA, MLA, Harvard, Chicago, Vancouver, etc.

You can also download the full text of the academic publication as pdf and read online its abstract whenever available in the metadata.

Browse journal articles on a wide variety of disciplines and organise your bibliography correctly.

1

Pistone, Pasquale. "Towards European international tax law." EC Tax Review 14, Issue 1 (2005): 4–9. http://dx.doi.org/10.54648/ecta2005002.

Full text

APA, Harvard, Vancouver, ISO, and other styles

2

Masuda, Hidetoshi. "Issues of International Tax Law." TRENDS IN THE SCIENCES 7, no. 12 (2002): 78–80. http://dx.doi.org/10.5363/tits.7.12_78.

Full text

APA, Harvard, Vancouver, ISO, and other styles

3

Pires, Manuel. "Quo Vadis International Tax Law?" Intertax 29, Issue 12 (2001): 394–95. http://dx.doi.org/10.54648/390801.

Full text

APA, Harvard, Vancouver, ISO, and other styles

4

Dyppel, Katja Joo, and Jakob Bundgaard. "Profit-Participating Loans in International Tax Law." Intertax 38, Issue 12 (2010): 643–62. http://dx.doi.org/10.54648/taxi2010069.

Full text

Abstract:

The article analyses the tax classification and tax treatment of profit participating loans (PPL) in international tax law. In order to analyse the tax aspects of PPL, the commercial and economic background is provided. Following this, a comparative overview of the tax law classification in the United States and Germany and an in-depth analysis of the tax classification and treatment in Danish law are provided. Next, the article analyses whether payments under PPL fall under the scope of the EU corporate tax directives and also considers the income tax treaty protection of payments under PPL.

APA, Harvard, Vancouver, ISO, and other styles

5

Rosembuj, Tulio. "International Tax Arbitrage." Intertax 39, Issue 4 (2011): 158–68. http://dx.doi.org/10.54648/taxi2011019.

Full text

Abstract:

The end of this decade leaves us with a scenario bare of any justification. There was not only the pursuit of certain logic for immediate profits but also the global aim to turn taxes (both local and international) into profits. Arbitrage was aimed to take advantage of differences in prices, and tax arbitrage went a step further aiming to turn the tax advantage into price. The aim was not solely to minimize the tax impact but also to add financial profits to the tax profit, which then became a source of income. The general principle against tax evasion establishes the restriction of any abusiv

APA, Harvard, Vancouver, ISO, and other styles

6

Andrianova, Natalia. "Low-Tax Jurisdictions in International Tax Planning." Russian Law Journal 9, no. 3 (2021): 137–62. http://dx.doi.org/10.17589/2309-8678-2021-9-3-137-162.

Full text

Abstract:

Until recently low-tax jurisdictions have played an important role in the formulation of tax planning schemes by multinational enterprises. However with the onset of global trends towards deoffshorization, existing methods of tax optimization have seen significant changes. As there is currently no one single approach when creating the definition of, or defining a “low-tax jurisdiction”, in this article the definition and the main features of lowtax jurisdictions are proposed and the main stages in the formation and development of low-tax jurisdictions are detailed. On the basis of research car

APA, Harvard, Vancouver, ISO, and other styles

7

Broekhuijsen, Dirk, and Irma Mosquera Valderrama. "Revisiting the Case of Customary International Tax Law." International Community Law Review 23, no. 1 (2021): 79–103. http://dx.doi.org/10.1163/18719732-12341459.

Full text

Abstract:

Abstract Customary international tax law has traditionally not received a lot of acclaim in international tax law literature. However, the infrastructure of international tax law is becoming increasingly multilateral. The recent adoption of the Multilateral Instrument and the creation of the Inclusive Framework, two initiatives related to the OECD/G20 Base Erosion and Profit Shifting Project, have accelerated the width of cooperation on international tax matters. For that reason, the authors (re)consider the existence of customary international law in the area of international tax law. They co

APA, Harvard, Vancouver, ISO, and other styles

8

Kyungseok Oh. "Review of Cases in 2014 ‘Corporate Tax Law’ and ‘International Tax Law’." Seoul Tax Law Review 21, no. 2 (2015): 409–39. http://dx.doi.org/10.16974/stlr.2015.21.2.011.

Full text

APA, Harvard, Vancouver, ISO, and other styles

9

Cappelen, Alexander W. "The Moral Rationale for International Fiscal Law." Ethics & International Affairs 15, no. 1 (2001): 97–110. http://dx.doi.org/10.1111/j.1747-7093.2001.tb00346.x.

Full text

Abstract:

A country's right to levy taxes is a fundamental aspect of its sovereignty. Without the power to tax, a government would be unable to redistribute resources among its citizens and provide public goods. The question of how tax rights should be distributed is therefore one of the oldest and most important problems of tax theory. Increased international economic integration has made this question even more important, as a larger share of economic transactions take place across national borders, giving rise to situations in which more than one country is able to tax the same base.How such conflict

APA, Harvard, Vancouver, ISO, and other styles

10

Sormin, Aflintua H., Alhabieb Amanggori, and Dr Prianto Budi Saptono. "Indonesian Double Tax Avoidance (P3B) In International Tax Law." International Journal of Scientific and Research Publications (IJSRP) 11, no. 8 (2021): 257–59. http://dx.doi.org/10.29322/ijsrp.11.08.2021.p11635.

Full text

APA, Harvard, Vancouver, ISO, and other styles

11

Kushu, S. O. "BASES OF MODERN INTERNATIONAL TAX LAW." Scientific bulletin of the Southern Institute of Management, no. 2 (June 30, 2017): 24–27. http://dx.doi.org/10.31775/2305-3100-2017-2-24-27.

Full text

Abstract:

International tax law is one of the most important components of international taxation, since it contributes to the establishment of universal principles for the collection of taxes in the globalizing system of world economic relations, and also affects the transparency of the borders between national tax jurisdictions. International legal regulation of taxation is designed to solve numerous disputes between different countries of the world, the conflict of national legal systems in a kind of struggle for the right to impose incomes of subjects of international economic relations. In a broad

APA, Harvard, Vancouver, ISO, and other styles

12

Bogenschneider, B. "FACTUAL INDETERMINACY IN INTERNATIONAL TAX LAW." BRICS Law Journal 3, no. 3 (2016): 73–102. http://dx.doi.org/10.21684/2412-2343-2016-3-3-73-102.

Full text

APA, Harvard, Vancouver, ISO, and other styles

13

van der Laan, Robert A. "Computer software in international tax law." Intertax 19, Issue 5 (1991): 266–73. http://dx.doi.org/10.54648/taxi1991043.

Full text

APA, Harvard, Vancouver, ISO, and other styles

14

Hussein Mohamed, Alaa, Hesham Ahmed Mahmoud, Ayman Ahmed Aly, and Ragab Abd El Zaher Aly. "International tax law and its sources." International Journal of Advanced Research on Law and Governance 3, no. 2 (2021): 172–82. https://doi.org/10.21608/ijarlg.2021.413749.

Full text

APA, Harvard, Vancouver, ISO, and other styles

15

Erdem, Muhammet Emre, and İmran Arıtı Erdem. "THE POSITION OF INTERNATIONAL TAX TREATIES IN DOMESTIC LAW." E-journal of New World Sciences Academy 14, no. 2 (2019): 1–24. http://dx.doi.org/10.12739/nwsa.2019.14.2.4c0228.

Full text

APA, Harvard, Vancouver, ISO, and other styles

16

Borgsmidt, Kirsten. "Eeotaxes in the Framework of Community Law." European Energy and Environmental Law Review 8, Issue 10 (1999): 270–81. http://dx.doi.org/10.54648/eelr1999043.

Full text

Abstract:

The requirements of Community law to be met when setting up an ecotax derive from the fundamental principle of free circulation, and from different fields of law having different goals: the purpose of environmental law is environmental protection, whereas the purpose of international tax law is neutrality of tax measures. Community tax rules are deeply rooted in international (GATT/ WTO) law which still governs trade relations with third countries. International competitiveness is not to he distorted by tax measures. International law offers the instrument of border tax adjustment to ensure th

APA, Harvard, Vancouver, ISO, and other styles

17

Bundgaard, Jakob. "Debt-flavoured Equity Instruments in International Tax Law." Intertax 42, Issue 6/7 (2014): 416–26. http://dx.doi.org/10.54648/taxi2014040.

Full text

Abstract:

Debt and equity can be structured to resemble one another through hybrid financial instruments. In this contribution the emphasis is on the tax issues related to debt-flavoured equity instruments in international tax law. This most important example of such instruments is preference shares. The article introduces the financial construction of preference shares and presents the rationale behind the existence hereof. As the main contribution the article presents an analysis of the international tax law aspects of preference shares, which includes a comparative overview, emphasizing the domestic

APA, Harvard, Vancouver, ISO, and other styles

18

Tlepina, Sholpan, Bakizhan Seidesh, Askar Kudaibergenov, Aigerim Zhunusbekova, Galym Bulatov, and Yerdos Murzagaliyev. "Current State and Evolution of the Concept of International Tax Law in the Context of Environmental Challenges: An Example of a Carbon Tax." European Energy and Environmental Law Review 30, Issue 3 (2021): 85–93. http://dx.doi.org/10.54648/eelr2021009.

Full text

Abstract:

The existence of international tax law as a branch of law and a scientific discipline often causes controversy, since there is no international tax. There is a regulatory area that defines the laws that apply to taxation, activities carried out in two or more countries, tax relations with a foreign element. Current international environmental initiatives seem to be a powerful argument in favour of the development and expansion of international tax law. The work considers the issue of introducing a carbon tax as an actual component and evolutionary stage of such a concept. At the same time, the

APA, Harvard, Vancouver, ISO, and other styles

19

Braumann, Céline. "Taxes and Custom: Tax Treaties as Evidence for Customary International Law." Journal of International Economic Law 23, no. 3 (2020): 747–69. http://dx.doi.org/10.1093/jiel/jgaa019.

Full text

Abstract:

ABSTRACT Scholars of public international law have not paid attention to international tax law in the past. This article seeks to fill this vacuum and to foster cross-field research by studying customary international law in international tax law. It assesses the value of international tax law’s most prominent feature for the identification of custom: the dense network of almost identical, bilateral double tax treaties. The primacy of source-based taxation for business profits serves as a test case for this purpose. The International Law Commission’s conclusions on the identification of custom

APA, Harvard, Vancouver, ISO, and other styles

20

Andrés Aucejo, Eva. "Towards an International Code for administrative cooperation in tax matter and international tax governance." Revista Derecho del Estado, no. 40 (December 13, 2017): 45–85. http://dx.doi.org/10.18601/01229893.n40.03.

Full text

Abstract:

There is not a “Global Code” that encodes the duty of cooperation between tax authorities in the world, concerning the global tax system. This article addresses this issue by proposing a global Code of administrative cooperation in tax matters including both tax relations: between States, and between States, taxpayers and intermediary’s agents. It follows a wide concept of tax governance. The findings of this research have highlighted several practical applications for future practice. article analyses, firstly, the State of the question, starting with the legal sources (international and Euro

APA, Harvard, Vancouver, ISO, and other styles

21

Mosquera Valderrama, Irma Johanna. "BEPS principal purpose test and customary international law." Leiden Journal of International Law 33, no. 3 (2020): 745–66. http://dx.doi.org/10.1017/s0922156520000278.

Full text

Abstract:

AbstractThe overall aim of this article is to analyse the principal purpose test as an emerging rule of customary international tax law. By means of the principal purpose test, the tax administration can deny the tax treaty benefit if one of the principal purposes of the action undertaken by the taxpayer was to obtain a benefit. This principal purpose test has been developed by the OECD with the political support of the G20 as one of the actions to tackle Base Erosion and Profit Shifting by multinationals (BEPS Project). At the time of writing, 137 jurisdictions including non-OECD, non-G-20 co

APA, Harvard, Vancouver, ISO, and other styles

22

Oliver, J. David B. "Resolving International Tax Disputes." Intertax 31, Issue 10 (2003): 313. http://dx.doi.org/10.54648/taxi2003062.

Full text

APA, Harvard, Vancouver, ISO, and other styles

23

Reilingh, Daniel de Vries. "The Concept of Permanent Establishment: A Comparative Analysis of Tax Treaty and Swiss Domestic Tax Law." Intertax 38, Issue 11 (2010): 577–87. http://dx.doi.org/10.54648/taxi2010061.

Full text

Abstract:

The author examines the concept of permanent establishment (PE) under Swiss tax law from a comparative Tax Treaty perspective and finds that this concept in the Federal Direct Tax Law (FDTL) is influenced by international tax law, although differences exist. He then identifies major differences between Swiss intercantonal tax law and the FDTL, and also international tax law. He is of the opinion that the PE concept of the FDTL, which is also valid in an international context, should be adopted in a Swiss intercantonal situation. He raises the question of whether the negative list of Article 5,

APA, Harvard, Vancouver, ISO, and other styles

24

Asllani, Shkumbin. "Domestic Anti-Avoidance Legislation in Relation to Tax Treaty Law." European Journal of Multidisciplinary Studies 6, no. 2 (2017): 312. http://dx.doi.org/10.26417/ejms.v6i2.p312-316.

Full text

Abstract:

In today’s international taxation most of the developing countries enter into tax treaties which are drafted in line with the OECD MC to eliminate double taxation. Yet, is well-known fact that tax treaties in practice are abused by tax payers, therefore, majority of states have introduce legislation specifically designed to prevent tax avoidance and protect their domestic interests. In legal practice and literature the act of overriding international tax treaties and denying treaty benefits in favour of domestic law provisions threatens main principle of international law and therefore is ques

APA, Harvard, Vancouver, ISO, and other styles

25

Anđelković, Mileva. "CONFIDENTIALITY VERSUS TRANSPARENCY IN CONTEMPORARY TAX LAW." Strani pravni život 61, no. 3 (2017): 81–95. http://dx.doi.org/10.56461/spz17306a.

Full text

Abstract:

Dilemma with regard to defining limit between tax confidentiality and tax transparency is particularly expressed in contemporary tax law. International tax relations indicate that countries tend towards fostering tax transparency with the expect of better collection of taxes and fair distribution of tax burden. The right to secrecy and confidentiality of personal data, as one of the basic rights, guarantees taxpayers that data collected about them shall be used only for the purpose of taxation. There are exceptions from tax secrecy which are prescribed by law or in cases when taxpayers volunta

APA, Harvard, Vancouver, ISO, and other styles

26

Farrell, Jennifer E., and Scott Wilkie. "Policy Forum: Reflections on the Relationship Between International Tax and Trade Law and Policy, and International Tax Avoidance." Canadian Tax Journal/Revue fiscale canadienne 73, no. 2 (2025): 319–32. https://doi.org/10.32721/ctj.2025.73.2.pf.farrell.

Full text

Abstract:

Tax policy and law, trade policy and law, and consequential perceptions of what constitutes "international tax avoidance" are intrinsically connected, but too often these fields are examined separately without a necessary awareness of this connection. However, without understanding this connection, and states' interests in relation to each other as mobilized among other ways through their tax systems, both the theoretical and practical coherence of tax and trade law are undermined. In addition, the profound distinction between impugnable international tax avoidance when contrasted with what is

APA, Harvard, Vancouver, ISO, and other styles

27

López Espadafor, Carlos María. "Trends and sources of international taxation = Tendencias y fuentes de la fiscalidad internacional." CUADERNOS DE DERECHO TRANSNACIONAL 11, no. 1 (2019): 438. http://dx.doi.org/10.20318/cdt.2019.4627.

Full text

Abstract:

Abstract: International Tax Law has grown significantly and this has caused a considerable increase in the importance of the legislative production affecting it, through both national and international rules. Within those rules of international origin, conventions intended to avoid international double taxation stand out, essentially those following the OECD model. Along with this and also within European Union law, there has been a significant structuring of the rules involving international taxation. That said, we can never lose sight -upon the basis of the dogmatic structuring of interna

APA, Harvard, Vancouver, ISO, and other styles

28

Weissbrodt, Jan. "Disaggregation of Financial Instruments in International Tax Law." Intertax 51, Issue 5 (2023): 414–26. http://dx.doi.org/10.54648/taxi2023037.

Full text

Abstract:

Disaggregation is the technique of decomposing a facts pattern into components and their separate legal subsumption. As a pre-step to prepare a legal case, it is an all too practical problem and therefore seems to be rather neglected in the high art of jurisprudence. This contrasts with the great importance of the substance over form doctrine in legal practice, being a universal and timeless issue in all fields of law dealing with economic subjects and in all jurisdictions. At the example of financial instruments as the ‘burning lens’ of tax law and the OECD Model Tax Convention (OECDMTC) as t

APA, Harvard, Vancouver, ISO, and other styles

29

Korvyakov, V. A. "System of sources and principles of international tax law." Uzhhorod National University Herald. Series: Law 3, no. 83 (2024): 372–77. http://dx.doi.org/10.24144/2307-3322.2024.83.3.58.

Full text

Abstract:

In international cooperation on taxation, countries strive to achieve equality in international taxation and, thus, create the basis for a fair international tax system. Justice exists in an international system of taxation only when states allocate taxing powers among themselves in a manner consistent with dominant views of justice internationally. A fair international tax system will not exist until there is some international consensus on how countries should allocate taxing powers among themselves. International cooperation allows countries to improve the coordination of tax policy at the

APA, Harvard, Vancouver, ISO, and other styles

30

De Pietro, Carla. "Tax Abuse and Legal Pluralism: Towards Concrete Solutions Leading to Coordination Between International Tax Treaty Law and EU Tax Law." EC Tax Review 29, Issue 2 (2020): 84–96. http://dx.doi.org/10.54648/ecta2020010.

Full text

Abstract:

As will be demonstrated in this article, the concepts of abuse adopted at EU and OECD level do not coincide completely. As a result of these differences, conflicts may concretely arise between the EU and international obligations held by the same EU Member State. Furthermore, due to legal pluralism (i.e. the fact that each legal system, in principle, is developed and, therefore, functions autonomously on a global level) very often, in case of conflict, different conflict rules will be applicable, without the possibility of guaranteeing coordination between international tax treaty law and EU t

APA, Harvard, Vancouver, ISO, and other styles

31

Ashiquzzaman, Md. "A Review of International Trade Law." International Journal of Tax Economics and Management 1, no. 2 (2018): 45–69. http://dx.doi.org/10.35935/tax/12.6945.

Full text

Abstract:

International trade law refers to the import and export of goods and other things between the two countries. For international trade, it is a very important matter in the business sector to know and observe international trade law in details. In this article we will discuss international trade and international trade law. Which is a very important issue in international trade. The aim of this article was to try to discuss all of the international trade issues. This is just a general review of the different aspects of international trade. There can be different laws or customs for a country or

APA, Harvard, Vancouver, ISO, and other styles

32

Dagan, Tsilly. "International Tax and Global Justice." Theoretical Inquiries in Law 18, no. 1 (2017): 1–35. http://dx.doi.org/10.1515/til-2017-0002.

Full text

Abstract:

AbstractInequality, as well as the scope of the duty of justice to reduce it, has always been a central concern of political justice. Income taxation has been seen as a key tool for redistribution and the state was the arena for discussions of justice. Globalization and the tax competition it fosters among states change the context for the discussion of distributive justice. Given the state’s fading coercive power in taxation and the decreasing power of its citizenry to co-author its collective will due to global competition, we can no longer assume that justice can be realized within the para

APA, Harvard, Vancouver, ISO, and other styles

33

Thömmes, Otmar. "The European dimension in international tax law." Intertax 18, Issue 10 (1990): 464–76. http://dx.doi.org/10.54648/taxi1990072.

Full text

APA, Harvard, Vancouver, ISO, and other styles

34

Pereira, Roberto Codorniz Leite. "The Emergence of Transparency and Exchange of Information for Tax Purposes on Request as an International Tax Custom." Intertax 48, Issue 6/7 (2020): 624–41. http://dx.doi.org/10.54648/taxi2020057.

Full text

Abstract:

In this article, the author contends that transparency and exchange of information on request became an international tax custom. The content of this new international tax custom is the exchange of information on request with regard to all tax matters for the administration and enforcement of domestic tax law without regard to a domestic tax interest requirement or bank secrecy for tax purposes with extensive safeguards to protect confidentiality of the information exchanged (the so called EOI Standard). The emergence of the EOI Standard as an international tax custom is a clear sign of change

APA, Harvard, Vancouver, ISO, and other styles

35

Lasinski-Sulecki, Krzysztof. "Is Soft Law Making Hard Law Too Hard?" Global Trade and Customs Journal 17, Issue 4 (2022): 171–76. http://dx.doi.org/10.54648/gtcj2022022.

Full text

Abstract:

Soft laws are created for many reasons to serve various purposes. This article focuses on acts of soft law that are adopted to facilitate the process of applying hard law (or complying with it) and to standardize the understanding of international agreements. In the field of customs law, one can point, for instance, to opinions adopted by the World Customs Organisation. The Organisation for Economic Co-operation and Development (the OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the Commentary to the OECD Model Tax Convention on Income and on Capita

APA, Harvard, Vancouver, ISO, and other styles

36

Jogarajan, Sunita. "Tax In History: The 100th Anniversary of International Institutions and International Taxation." Intertax 48, Issue 10 (2020): 929–33. http://dx.doi.org/10.54648/taxi2020091.

Full text

Abstract:

The year 2020 got off to an encouraging start. On 29-30 January 2020 … the 137 countries and jurisdictions of the G20/OECD Inclusive Framework on BEPS reaffirmed their commitment to reach a consensus-based solution and endorsed the ‘Outline of the Architecture of a Unified Approach on Pillar One.’(OECD, OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (Riyadh, Saudi Arabia) (OECD Publishing, Feb. 2020), available at http://www.oecd.org/ctp/oecd-secretary-general-tax-report-g20-finance-ministers-riyadhsaudi- arabia-february-2020.pdf (accessed 11 June 2020).)

APA, Harvard, Vancouver, ISO, and other styles

37

Cho, Hyejin. "Sustainable Tax Behavior of MNEs: Effect of International Tax Law Reform." Sustainability 12, no. 18 (2020): 7738. http://dx.doi.org/10.3390/su12187738.

Full text

Abstract:

As tax is related to the sustainable growth of societies around the world, international tax avoidance by multinational enterprises (MNEs) has gained public attention. The Organization for Economic Co-operation and Development (OECD) introduced the Base Erosion and Profit Shifting (BEPS) Action Plan to promote sustainable tax behavior of MNEs. To guide policymakers and regulators in curving MNEs’ tax schemes utilizing market imperfection, this paper empirically assesses whether the international law reform regarding information disclosures on global operation achieves the intended result of lo

APA, Harvard, Vancouver, ISO, and other styles

38

Yesimov, S. S. "International legal principles of combating tax offenses." Analytical and Comparative Jurisprudence, no. 6 (December 16, 2024): 564–68. https://doi.org/10.24144/2788-6018.2024.06.91.

Full text

Abstract:

The article examines the international legal principles of combating tax crime based on current legislation and the legislation of the European Union in a comprehensive and systemic aspect. The urgency of conducting scientific research is determined by the need to improve tools for preventing violations of tax and levy legislation, which take into account the inter-branch connections oftax and other branches of legislation. The object of the study was the social relations that develop during the implementation of the norms that provide for combating tax crimes. The subject of the study was int

APA, Harvard, Vancouver, ISO, and other styles

39

Zielke, Rainer. "International Tax Planning with Comtax." Intertax 37, Issue 3 (2009): 197–206. http://dx.doi.org/10.54648/taxi2009020.

Full text

Abstract:

International tax planning, especially with holding companies, is the most tax effective but also most demanding field of international tax planning, as numerous systems of taxation and their interrelation have to be taken into consideration and computer based systems are necessary. Whereas most of those systems are usually limited to providing basic information on corporate income tax systems, tax rates and the treaty network, the Comtax System provides not only current in-depth information on numerous national systems of taxation, but also quantifies cross border payment transfers, and thus

APA, Harvard, Vancouver, ISO, and other styles

40

Anggia, Putri. "The Influence of International Tax Policy on the Indonesian Tax Law." Yuridika 35, no. 2 (2019): 343. http://dx.doi.org/10.20473/ydk.v35i2.16873.

Full text

Abstract:

By 2012, the Indonesia government had validated Law Number 9 of 2017. One of the content is finance information government access to the customer bank and to the taxpayer. The government has considerations. First of all, Government will be open the access limitation of banking automatically that is necessary for taxation. The second, Indonesia has committed to international agreements of taxation which is obliged to fulfill the commitment. The commitment is to participate in implementing Automatic Exchange of Account Information (AEOI). Based on the policy, several managements and flow process

APA, Harvard, Vancouver, ISO, and other styles

41

Zasypkin, V. A. "Unfair tax competition and offshore jurisdictions: categories in international tax law." Courier of Kutafin Moscow State Law University (MSAL)), no. 8 (October 13, 2022): 156–68. http://dx.doi.org/10.17803/2311-5998.2022.96.8.156-168.

Full text

APA, Harvard, Vancouver, ISO, and other styles

42

Gadžo, Stjepan. "The Principle of Nexus or Genuine Link as a Keystone of International Income Tax Law: A Reappraisal." Intertax 46, Issue 3 (2018): 194–209. http://dx.doi.org/10.54648/taxi2018022.

Full text

Abstract:

In this article, the author analyses the legal status of the so-called ‘nexus principle’, i.e. the requirement that a qualifying connection exists between the state exercising its taxing power on the one hand and taxable subject and/or taxable object on the other. It is argued that the nexus principle forms part of general international law of income tax jurisdiction, since it has attained the status of international custom. Put differently, international customary law prohibits income taxation in the absence of both personal and territorial nexus. In the light of the well-established methodol

APA, Harvard, Vancouver, ISO, and other styles

43

Hilling, Axel. "Book Reviews 2015." Nordic Tax Journal 2015, no. 2 (2015): 143–49. http://dx.doi.org/10.1515/ntaxj-2015-0013.

Full text

Abstract:

Abstract This section contains three book reviews. First the book Swedish Taxation, Development since 1862 is reviewed. This volume comprises six studies that examine the development of Swedish taxation from 1862 to 2013, and will likely be of great value in future Nordic tax research because of its comprehensiveness. The second review is about a book written in Swedish:Momsfri sjukvård (The VAT exemption for health care). This volume discusses a topical issue and presents convincing recommendations for changes in the Swedish VAT legislation. Finally, the Danish book International Skatteret, i

APA, Harvard, Vancouver, ISO, and other styles

44

Gadžo, Stjepan, and Šime Jozipovic. "International Corporate Tax Regime Post-BEPS: A Regulatory Perspective." Intertax 48, Issue 4 (2020): 432–45. http://dx.doi.org/10.54648/taxi2020038.

Full text

Abstract:

Among the other rationales underlying the existence of corporate income tax (CIT) as a standalone tax on the profits derived by legal entities, some scholars have underlined its regulatory function, i.e. its potential to steer the behaviour of private sector actors. In this regard, it has to be noted that significant constraints on the use of CIT as a regulatory tool have emerged in the aftermath of the base erosion and profit shifting (BEPS) project. One example may be found in the new ‘modified nexus approach’ with regard to tax incentives for R&amp;D activities. This article takes a reg

APA, Harvard, Vancouver, ISO, and other styles

45

Stojanovic, Snezana. "International tax treaties override." Zbornik Matice srpske za drustvene nauke, no. 162 (2017): 347–63. http://dx.doi.org/10.2298/zmsdn1762347s.

Full text

Abstract:

International order is based on the consent of states and the principle pacta sunt servanda, thus making the treaty override a serious problem. When one party unilaterally overrules treaty provision(s), other party may undertake measures prescribed in the Vienna Convention on the Law of Treaties: termination or suspension. It is also possible to apply mutual agreement procedure. Usually, states avoid entering into re-negotiation of the treaties because it is time-consuming. The author differentiates between treaty override in monist and dualist states, and within the European Union, then makes

APA, Harvard, Vancouver, ISO, and other styles

46

Ozai, Ivan. "Two Accounts of International Tax Justice." Canadian Journal of Law & Jurisprudence 33, no. 2 (2020): 317–39. http://dx.doi.org/10.1017/cjlj.2020.8.

Full text

Abstract:

The contemporary international tax regime has been increasingly criticized over the years from varied perspectives, particularly as to the unfairness it produces for developing countries. Some commentators argue it is unjust due to the lack of participation of developing countries in the policymaking process on an equal footing. Others suggest the international tax regime was designed by affluent countries to respond to self-interested goals. Some note that its current institutional design creates opportunities for tax competition and avoidance, which more seriously affect developing economies

APA, Harvard, Vancouver, ISO, and other styles

47

Ferrers, Tony. "New Zealand International Tax Developments." Intertax 24, Issue 10 (1996): 388–96. http://dx.doi.org/10.54648/taxi1996066.

Full text

APA, Harvard, Vancouver, ISO, and other styles

48

Salehifar, Alireza. "Rethinking the Role of Arbitration in International Tax Treaties." Journal of International Arbitration 37, Issue 1 (2020): 87–130. http://dx.doi.org/10.54648/joia2020004.

Full text

Abstract:

The dispute resolution system of Double Tax Agreements (DTAs) has been a major focus for both tax authorities and researchers around the world. For several years Article 25 of the Model Tax Convention of the Organisation for Economic Co-operation and Development on Income and on Capital (‘OECD Model Tax Convention’), and Article 25 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (‘UN Model Tax Convention’) had relied on a negotiation-based Mutual Agreement Procedure (MAP) as the only mechanism for the resolution of disputes arising from a tax t

APA, Harvard, Vancouver, ISO, and other styles

49

Tychmanska, Aleksandra. "The OECD as the Future International Tax Organization: An Inevitable Course of Events?" Intertax 49, Issue 8/9 (2021): 614–35. http://dx.doi.org/10.54648/taxi2021064.

Full text

Abstract:

Over the years, the increasing process of tax law internationalization may be observed due to which tax cooperation between states expands and may take various forms. The leading international organization that creates a platform for the cooperation of states on tax matters and provides expertise in the scope of tax law is the Organization for Economic Co-operation and Development (OECD). This article focuses on the role that the OECD performs in the international arena and analyses its increasing significance over the decades as the organization providing platform for states to collaborate on

APA, Harvard, Vancouver, ISO, and other styles

50

Weißert, Sören. "Canadian MNCs International Tax Planning: Theory and Practice." Intertax 42, Issue 4 (2014): 276–89. http://dx.doi.org/10.54648/taxi2014028.

Full text

Abstract:

In this article, we analyse the role of international tax planning in Canadian MNCs outbound investment decisions in theory and practice. We identify the framework of international tax planning. We can show that international tax planning is an important factor (value driver) to influence the value of the whole firm (Canadian-based MNC group) and not only of a single investment project. We also introduce a new developed tax structure (tax engineering) for Canadian MNCs to apply international tax planning. According to this new tax management approach, the value of the whole group can be enhanc

APA, Harvard, Vancouver, ISO, and other styles

We offer discounts on all premium plans for authors whose works are included in thematic literature selections. Contact us to get a unique promo code!