International Tax
Is Incorporation the Solution to the Enigma of Corporate Tax Residency for International Tax Purposes?
... However, although incorporation would prescribe a more formalistic approach, this Article has attempted to argue that the economic reality inherent in a unified and uniform approach to incorporation could lead to an ...
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A Hitchhiker’s Guide to Outbound International Tax Reform
... although tax simplification is an important aspect of tax reform, it is not likely to be the major focus of serious international tax reform efforts, particularly with respect to taxation of ...
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China and the Future of the International Tax Regime
... The International tax regime (ITR) has been transformed after the Great Recession of ...single tax principle (income should be taxed once, ...single tax principle. In the US BEPS is almost ...
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The impact of globalisation on the position of developing countries in the international tax system
... of international taxation only in terms of economic ...on international investment income is to focus on maximising the US national welfare rather than global welfare which signifies that CEN might not ...
317
A Brief Analysis of the New Trend of International Tax Planning—TESCM
... the tax authorities of all countries pay more attention to the protection of the tax base and the contention of the tax ...integrate tax optimization into it. Now, the tax effi- cient ...
10
Criteria of International Tax Policy
... of tax treaties became fixed, the United States was a net capital exporter in all ...way tax treaties exempted interest and royalties from tax in the source country, and from tax treaties’ ...
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ESTIMATION OF INTERNATIONAL TAX PLANNING IMPACT ON CORPORATE TAX GAP IN THE CZECH REPUBLIC
... on tax motivated income shifting between parent companies and their affi ...marginal tax rates that jurisdictions ...to tax differentials through the use of transfer pricing mechanism, royalties, ...
15
International Finance and State Sovereignty: Global Governance in the International Tax Regime
... mobility of capital resource and business actIvIties driven by international economic integration have pushed governments to employ new tax mechanisms such as tax [r] ...
43
Issues of international tax and trade policy conflict and co operation
... i If the production- trade payoff to a bilateral agreement iidth a country in the same region is lower than the sponsorship cost then on the equilibrium path FTA in time t=1,2 at any poi[r] ...
204
International Tax Free Exchanges: The Structure of I.R.C. Section 367
... tion that receives stock of a domestic controlled corporation, and such controlled corpora- tion acquired the assets of the foreign distributing corporation pursuant[r] ...
24
Tax Reform in an Era of Budget Stress, Inequality, and International Mobility
... the tax side, much of the discussion has related to the possibility of increasing taxes on capital income, which has played a particular role in producing ...corporate tax rates for the G-7 plus Swit- ...
20
Мировой опыт оптимизации налогообложения: роль налоговой конкуренции и оффшорных центров в мировом хозяйстве
... Review, National Tax Journal, European Journal of Political Economics, Fiscal Studies, International Tax and Public Finance, Journal of Public Economics, Public Choice, Perspektiven der [r] ...
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What Makes a Country a Tax Haven? An Assessment of International Standards Shows Why Ireland Is Not a Tax Haven
... The Tax Justice Network (TJN), an NGO that seeks to promote transparency in international tax and finance matters, argues that tax havens undermine the interests of poor ...of tax ...
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Bilateral Tax Treaties and Foreign Direct Investment in India: Evidence from Mauritius
... The international tax treaties have significant impact on the flow of Foreign Direct Investment (FDI) of a ...bilateral tax treaties on the flow of FDI between India and ...
9
The Logic and Issues of International Regional Tax Integration
... of international regional tax integration. The international economic integration has two mainstreams: global and regional economic ...global tax integration is concerned only with double ...
10
The role of international public goods in tax cooperation
... of international tax ...an international public good, namely a public good whose benefits can extend beyond national boundaries (see Bjorvatn and Schjelderup, 2002, and Tabellini, ...of ...
27
Ireland's Tax Expenditure System: International Comparisons and a Reform Agenda
... pension tax expenditure is merely a deferral of taxable income, since pensions payable are fully ...the tax benefits relating to pension contributions are threefold. Tax, PRSI and health contribution ...
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The Tax Transparent Entity in the International Conflict of Laws
... The Tax Transparent Entity in the International Conflict of Laws SMU Law Review Volume 68 | Issue 3 Article 10 2015 The Tax Transparent Entity in the International Conflict of Laws Richard M Buxbaum U[.] ...
15
The Permanent Establishment Concept In Double Tax Agreements Between Developed And Developing Countries: Canada/South Africa As A Case In Point
... However, the UN model denies a deduction for head office expenses where those expenses are payments for royalties, fees, interest, and commissions for specific management services. The UN model therefore provides for a ...
14
Competing for a duopoly : international trade and tax competition
... corporate tax rates (or an up- ward pressure on subsidy payments) are suggested by existing formal analyses of tax/subsidy competition for ...capital tax creates a positive externality as capital is ...
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