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...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

With opening of the economy in 1991 and subsequent removal of regulatory and trade barriers, India became an attractive investment (Foreign Direct Investment-FDI) destination. A large number of multinationals have established operations in India to utilise the services of available skilled...

The World Customs Organization (Organisation Mondiale des Dounaes) is an intergovernmental organization of more than 170 Member States that was founded as European Customs Cooperation Council in 1952. This paper gives a brief overview of its history and legal milestones.

The Nomenclature that is governed by the Convention on the Harmonized Commodity Description and Coding System (Harmonized System Convention, Brussels, 14 June 1983) has resulted in an adjustment of many nomenclatures used worldwide for statistical and customs classifi cation because...

It contains a summary of disputes concerning income tax measures that have arisen at the WTO since its establishment, with special attention to the protracted dispute between the EC and the US over the latter's FSC/ETI schemes.

The author discusses the International Tax Transparency in Venezuela after the implementation of the worldwide taxation system. A detailed analysis is made of the law providing the legal, economic and potential consequences of the use of tax havens by Venezuelan taxpayers. Finally, the issue of...

The international corporate income and capital gains tax (CGT) systems of basically all modern nation states share a common objective. All seek to effectively ‘capture' multinational enterprises (‘MNEs') that are economically present within the respective taxing state's geographical borders...

Managing tax risk is one of the greatest challenges for tax departments around the world (creating the opportunities to build relationships with revenue services), starting with the verification audit through to the resolution of tax controversies. A recent survey supports this contention. Key...

Since the early 1990s the issue of fiscal transparency has attracted increasing attention from international institutions, governments, and NGO's concerned with budgets and fiscal policy reform. This Article offers a critical analysis of the meaning and purposes of fiscal transparency in light...