In this article, the author discusses the saving clause in the OECD’s multilateral instrument and potential problems that may result from its application, and concludes that for a majority of OECD member states, adopting the clause may not be appropriate
This Article considers some possible implications for the international tax regime based on three ma...
The international tax regime is facing a defining moment. As stories of multinational companies expa...
The OECD's public discussion draft 'BEPS Action 6: Preventing the Granting of Treaty Benefits in Ina...
This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts w...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
In this article, the authors consider some of the practical issues relating to the introduction of t...
Model tax treaties do not require tax rate coordination, but do call for either credits or exemption...
The benefits of a tax treaty are generally granted to persons who are residents of one of the Contra...
Special Issue: International Tax Challenges for Developing CountriesDeveloping countries frequen...
The subject of the article. The article represents a research of conceptual properties and issues of...
Action 15 of the OECD/G-20 Base Erosion and Profit Shifting (BEPS) project is to "develop a multilat...
Internationalization offers enhanced opportunities for individuals to place savings abroad and evade...
This article analyses the international tax principles in double tax treaties regarding the allocati...
Tax avoidance through international treaty shopping has become a subject of intense controversy in t...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
This Article considers some possible implications for the international tax regime based on three ma...
The international tax regime is facing a defining moment. As stories of multinational companies expa...
The OECD's public discussion draft 'BEPS Action 6: Preventing the Granting of Treaty Benefits in Ina...
This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts w...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
In this article, the authors consider some of the practical issues relating to the introduction of t...
Model tax treaties do not require tax rate coordination, but do call for either credits or exemption...
The benefits of a tax treaty are generally granted to persons who are residents of one of the Contra...
Special Issue: International Tax Challenges for Developing CountriesDeveloping countries frequen...
The subject of the article. The article represents a research of conceptual properties and issues of...
Action 15 of the OECD/G-20 Base Erosion and Profit Shifting (BEPS) project is to "develop a multilat...
Internationalization offers enhanced opportunities for individuals to place savings abroad and evade...
This article analyses the international tax principles in double tax treaties regarding the allocati...
Tax avoidance through international treaty shopping has become a subject of intense controversy in t...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
This Article considers some possible implications for the international tax regime based on three ma...
The international tax regime is facing a defining moment. As stories of multinational companies expa...
The OECD's public discussion draft 'BEPS Action 6: Preventing the Granting of Treaty Benefits in Ina...