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The article will show what is meant by the concept of evidence and means of evidence in terms of the Tax Procedure Code, and also in terms of the legal doctrine.In the fiscal procedural law the concept of evidence is used in a narrow sense. Therefore, the notion of evidence is the legal means...
Persistent link: https://www.econbiz.de/10013123212
One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...
Persistent link: https://www.econbiz.de/10013096911
By taking the Great Wall of China as an analogy for China's treaty policy, the author considers key aspects of China's treaty network and its implications, and whether or not this constitutes a “Great Fiscal Wall of China.”Cited with the permission of IBFD
Persistent link: https://www.econbiz.de/10013099578
Bilateral and regional trade and investment treaties (‘FTAs' and ‘BITs') have proliferated in the Asia-Pacific region, along with double-tax treaties (‘DTTs'). But countries like Australia have recently become more concerned about FTAs and BITs. This article examines processes that states...
Persistent link: https://www.econbiz.de/10013106133
Free zones have become increasingly popular as trade promotion policy instruments in developing countries. This article explains how the obligations in the WTO Agreement on Subsidies and Countervailing Measures apply to free zones. An analysis of the most common requirements for companies...
Persistent link: https://www.econbiz.de/10013109226
As the need to raise revenue becomes more pressing and public opposition to tax avoidance increases, the European Court of Justice has made it more difficult for the twenty-seven Member States of the European Union to prevent tax avoidance and shape fiscal policy. This article introduces the new...
Persistent link: https://www.econbiz.de/10013081257
Recently, in CIBC World Markets Inc. v. R. (“CIBC case”), the Chief Justice of the Tax Court of Canada (“TCC”) was faced with an issue that was novel to Canada's consumption tax jurisprudence. Can a GST registrant retrospectively change its method for allocating input taxes between its...
Persistent link: https://www.econbiz.de/10013083339
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...
Persistent link: https://www.econbiz.de/10013083814
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...
Persistent link: https://www.econbiz.de/10013083816
The main objective of the European economical community treaty was to remove the economical barriers between the European member states. For this purpose, the treaty established the single market which has at the base of its function the fourth liberties: the free movement of goods, persons,...
Persistent link: https://www.econbiz.de/10013085450