This paper analyzes the differences in legal nature between the common law concept of Agency and the civil law concept of Commissionaire in light of articles 5(5) and 5(6) of the OECD Model Tax Convention. The author contradicts the idea of interpreting the civil law concept of Commissionaire is...

Over time, the use of most favoured nation clauses has seen widespread adoption in double tax treaties, especially in those agreed with developing countries. The use of such clauses, however, does not appear to have been supported frequently by tax policies and/or careful ad hoc analysis, e.g....

Place of taxation rules are the seminal cross-jurisdictional provisions of any consumption tax regime. They determine where among competing jurisdictions a particular service is taxed. They are not important for transactions that are restricted to a single jurisdiction and to businesses or...

Während in Deutschland wieder einmal der Abbau der kalten Progression angemahnt wird, gibt es in vielen anderen Staaten bereits Regelungen zur Vermeidung von inflationsbedingten Steuererhöhungen. Aber welchen genauen Befund liefert ein internationaler Vergleich und welche Einsichten lassen...

This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: “accounting and financial risks adjustments” and...

Paying taxes is a cost of doing business. The looters (or public servants, depending on your perspective) must be paid and tax proceeds must be distributed to various groups and individuals, both worthy and unworthy. But tax expense includes more than just the amount of taxes that must be paid....

This paper seeks to expose the origins and impacts of electronic commerce on tax revenues, especially with regard to services and intangibles good transferable via download, making an analysis of the international scenario. Therefore, portrays the rise of the internet and its popularization,...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This paper provides a brief comparative analysis between the Controlled Foreign Corporations rules ("CFCs rules") in Latin American countries and in the United States, the pioneer country in developing this kind of anti-deferral rules in 1962. The author concludes that the effectiveness of the...