Double Tax Treaties and Their Interpretation
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چکیده
منابع مشابه
An Analysis of Double Taxation Treaties and their Effect on Foreign Direct Investment
Double taxation treaties are intended to eliminate double taxation, thereby encouraging FDI, and prevent tax evasion, which previous literature argues will have a negative effect on FDI. Using a segmented data set and matching econometrics, I show that double taxation treaties have no effect on FDI from developed to less developed countries and substantiate why: Developed countries unilaterally...
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In the last decades all over the world pension policy reforms have tried to account for the changing demographic and socio-economic framework. An excellent starting point for economic analyses of reform strategies is the Mirrlees Review which argues that pension policy should simultaneously address pension benefit design and the taxation of pensions. We focus on old-age pension taxation and add...
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and general language. Also, the discussion drafts do not clarify the context, object, and purpose to be considered in the interpretation of beneficial owner. Regarding the context, the drafts only explain that ‘‘the term ‘beneficial owner’ was added to address potential difficulties arising from the use of the words ‘paid to . . . a resident’ in paragraph 1,’’19 but they leave unspoken exactly ...
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Tax treaties are often viewed as a mechanism for eliminating tax competition, however this approach ignores the need for bargaining over the treaty’s terms. This paper focuses on how bargaining can affect the withholding taxes set under the treaty. In a simple framework, we develop hypotheses about patterns in treaty tax rates. A key determinant for these patterns is the relative size of bilate...
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