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Persistent link: https://www.econbiz.de/10010343058
Smart contracts are the latest twist on automated programming. Their tax implications are still emergent: regulators may seek to fight, join, or try to dominate the market for virtual assets in direct competition with the ambitions of private law orders. This paper reviews the technology to date...
Persistent link: https://www.econbiz.de/10012837605
This paper discusses the implications for tax systems of globalization of capital markets and of economies. It shows the extent to which particular taxes are affected by the globalization process. It speculates on future developments in this area and on tax competition
Persistent link: https://www.econbiz.de/10012781971
Over the past few years, policymakers have argued that everything from Apple's Irish tax deal to patent boxes to the LuxLeaks tax rulings represent “harmful tax competition.” Despite the ubiquity of this term, however, there is no internationally accepted definition of so-called harmful tax...
Persistent link: https://www.econbiz.de/10012902342
We have several kinds of measures for mitigating or eliminating international double taxation and stimulating international trade. Some of them are unilateral, the others are bilateral, and still others are multilateral. A natural question here: why we have all these measures? The answer lies in...
Persistent link: https://www.econbiz.de/10012898985
Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...
Persistent link: https://www.econbiz.de/10012850635
This paper investigates offshore financial centers in the Caribbean from the perspective of offshore economies, onshore … funds that has been transferred from the major banking systems to offshore financial centers located in the Caribbean and … vice versa. We highlight that Caribbean offshore financial centers have been predominantly used by persons, resident in the …
Persistent link: https://www.econbiz.de/10013059270
Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries....
Persistent link: https://www.econbiz.de/10012984282
The appeal of McKesson Canada Corporation (McKesson Canada) has been heard by the Tax Court of Canada which published its decision on 13 December 2013. The Court found for the Canada Revenue Agency (CRA), accepting the CRA's factoring discount of 1.013% in place of that to which the taxpayer had...
Persistent link: https://www.econbiz.de/10013047325
Many countries seek to attract wealthy individuals — their capital, if not actually themselves — with programs that confer residence or citizenship in exchange for specified investments in local property or business ventures. Some programs simply facilitate jumping the immigration line,...
Persistent link: https://www.econbiz.de/10012930637