January 2025: Tax Alert (English/Chinese) VAT rate increases to 12% as from 1 January 2025 October 2024: Tax Alert (English/Chinese) Gearing up for Pillar Two global minimum tax and subject to tax rule in Indonesia January 2024: Tax Alert (English/Chinese) Effective tax rate to calculate ...
The OECD Model Tax Treaty: Tax Competition and Two-Way Capital Model tax treaties do not require tax rate coordination, but do call for either credits or exemptions when calculating a multinational's domestic taxes. Th... RB Davies - 《University of Oregon Economics Department Working Papers》 ...
This special rule of treaty interpretation essentially directs that, unless the context otherwise requires, an undefined treaty term must be given the meaning it has under the law of the state applying the treaty. This article examines the reference to domestic law and focuses in particular on ...
China Spain Turkey Germany Japan Romania Portugal Netherlands Further, all individuals who might have never formally abandoned their lawful permanent residency (“green card”), maybe never filed specific IRS tax forms, and yet reside in one of these fourteen (14) treaty countries could be eligibl...
• Hong Kong-Mauritius tax treaty in force Issue 187 - 27 June 2023 • Passage of tax measures proposed in the 2022 Policy Address and the 2023-24 Budget speech Issue 186 - 26 June 2023 • Views exchanged in the 2022 annual meeting between the Inland Revenue Department and HKICPA ...
interpretationinternational tax lawtax lawtaxationdouble tax conventionsThis study takes a fresh, thorough look at the interpretation and application of Article 3(2) and submits a new approach that transcends the current controversiSocial Science Electronic Publishing...
French High Tax Court Confirms that the Former France–Switzerland Tax Treaty Overrides the French CFC Legislation PY Bourtourault,MN Mbwamboma 被引量: 3发表: 2002年 Tax Treatment of US S-Corporations under the Germany-US Tax Treaty. The article discusses a court decision made by the German ...
Comparing tax revenues to be raised by developing countries from the Amount A and the UN Model Treaty Article 12B Regimes. Tandon, S., & Rao, C. (2022). Evaluating the impact of Pillars One and Two (No. 165). Research Paper. The Joint Committee on Taxation, Congress of the United ...
global evolutionOECD ModelArticle 9The allocation norm regarding the profits of associated enterprises, now encapsulated in Article 9 of the OECD and UN Model Conventions, is engaged in a creepinBaistrocchi, Eduardo ASocial Science Electronic Publishing...
straightforward when dealing with the situation of a resident of one country deriving income or gain from the other country, but not actually residing there. However, for the US person living in the UK (i.e., resident of both countries), the application of the treaty becomes more complex...