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Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...
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multipart project titled Base Erosion and Profit Shifting (BEPS), which contains 15 "Actions" to prevent multinational … budgets are strained, the world economy is struggling, income inequality is rising, and the news media have publicized … tax incentives for research and development (R&D), implementation of the BEPS Actions would drive many MNCs to relocate …
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, have responded with projects to rid the world of so-called harmful tax practices. The OECD's project has implications for …
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BEPS Action 5 is one of the four minimum standards which all members of the OECD/G20 Inclusive Framework on BEPS have … exchange of information on certain tax rulings which, in the absence of transparency, could give rise to BEPS concerns. 140 …
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