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emanate from tax treaty implementation in China. In these cases, U.S. (and other foreign) investors face certain rules that …. The question arises as to whether U.S. taxpayers should contest such rules in China. Equally, the IRS faces the question …
Persistent link: https://www.econbiz.de/10013236614
The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting...
Persistent link: https://www.econbiz.de/10012606701
This article examines the impact of the international tax system on the location decision of a foreign permanent establishment (PE) including cross-border loss relief and activity clauses. Germany, e.g., operates a hybrid system of international taxation, under which foreign income from PEs...
Persistent link: https://www.econbiz.de/10014263780
Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...
Persistent link: https://www.econbiz.de/10014177429
Developing countries need fiscal revenue to build their infrastructure, achieve energy security and environmental sustainability, and provide social services necessary for human development. While trade and investment treaties have typically been assumed to be tax revenue-neutral, economic...
Persistent link: https://www.econbiz.de/10013322806
The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...
Persistent link: https://www.econbiz.de/10013337674
Persistent link: https://www.econbiz.de/10001285324
China attracted considerable foreign investment following the opening of its economy in 1979. With the switch to a … quasi-market economy, China became reliant on taxes to fund government, opening the door to potential double taxation of … profits from foreign investment, first in China and second in the investors' home countries. The issue was resolved in a …
Persistent link: https://www.econbiz.de/10012943631
The Department of Finance (Canada) appointed an Advisory Panel on Canada’s System of International Taxation (the ‘Advisory Panel’) to review and recommend changes to Canada’s international tax regime. This report provides background research to assist the Advisory Panel with its...
Persistent link: https://www.econbiz.de/10014204803
This paper examines the investments made by China in key African countries and analyses the effects of such investment … measures are. The risks identified in this study will be evaluated against the actual or potential benefits arising from China … doing, benefit fully and responsibly from China’s interest in Africa …
Persistent link: https://www.econbiz.de/10013242837