To what degree developing countries gain from signing double tax treaties is being hotly debated. In this paper, we analyze the Austrian tax treaty policy. Combining legal and economic perspectives, we find that developing countries are likely to expect both positive and negative impacts from...

The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

The paper provides an analysis of the key practical issues to eliminate double taxation of business income in the Netherlands. Both the methods for relieving juridical double taxation and the methods for relieving economical double taxation (e.g. participation exemption regime) are adressed

As companies seek to expand their operations, globally, a major regulatory bottleneck they encounter is that of Double Taxation. This portends a sort of nauseating feeling for investors who might find the tax burden too heavy to bear. Issues ranging from tax avoidance to outright evasion have...

This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority Guidance Plan. Recommendations in this letter cover various treaty abuse situations

This article examines the international tax treaty policy of the Netherlands in respect of the negotiations of double tax conventions (DTCs) including the relevant parts of the Memorandum Tax Treaty Policy 2011 published by the Minister of Finance in the Netherlands. It further analyzes the DTC...