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.The conclusions reached in this article are that the Commentary is not legally binding although courts around the world …
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around the world, if those countries ratify the MLI.In November 2017, the PPT rule was also included in article 29(9) of the …
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The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institutions" resident in OECD countries, as well as in...
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. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties …
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