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Domestic Anti-Abuse Rules and Double Taxation Treaties : A Spanish Perspective – Part I
Martin Jimenez, Adolfo - 2014
Spain) that the tax norm, as a norm that restricts individual rights, must be interpreted strictly and cannot therefore be … competition may slow down dramatically. 4) In Spain’s tax system, the General Tax Law (Ley General Tributaria, hereafter “GTL … that the tax jurisprudence in Spain has added a fourth instrument the “indirect business” theory (the “indirect business …
Persistent link: https://www.econbiz.de/10014037042
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Reconstructing the Treaty Network - EU report
Pinto Nogueira, João Félix; Pistone, Pasquale; Garcia … - 2020
This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...
Persistent link: https://www.econbiz.de/10014095441
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Portugal : PE and Non-Discrimination Regarding Domestic Relief for Double Economic Taxation
Pinto Nogueira, João Félix - 2022
This article examines a Portuguese decision on the application of a tax treaty's non-discrimination clause to extend the domestic relief available under domestic law to a person that, according with the wording of such clause, would be excluded from it.In this case, the author believes that the...
Persistent link: https://www.econbiz.de/10013299941
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OS ECJ-TF 1/2015 of the CFE on the Decisions of the European Court of Justice in Commission v. Spain (Case C-127/12) and Commission v. Germany (Case C-211/13) Concerning Inheritanc...
Pinto Nogueira, João Félix - 2020
the compatibility of inheritance taxation with the fundamental freedoms (Commission v. Spain (Case C-127/12) and …
Persistent link: https://www.econbiz.de/10012829030
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The Interpretation of Plurilingual Tax Treaties : Routine Interpretation — A Refutation
Resch, Richard Xenophon - 2020
Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...
Persistent link: https://www.econbiz.de/10012850635
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Withholding tax rates on dividends : symmetries vs. asymmetries in double tax treaties
Petkova, Kunka - 2020 - This version, 14 February 2020
Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...
Persistent link: https://www.econbiz.de/10012216199
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On the relevance of double tax treaties
Petkova, Kunka; Stasio, Andrzej; Zagler, Martin - 2018
This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network, since FDI can flow from home to host...
Persistent link: https://www.econbiz.de/10011799275
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International Tax Neutrality : Revisited
Shaheen, Fadi - 2013
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
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International Tax Neutrality : Reconsiderations
Shaheen, Fadi - 2013
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
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The effect of double taxation treaties and territorial tax systems on foreign direct investment : evidence for Spain
Castillo-Murciego, Ángela; López Laborda, Julio - 2019
The paper evaluates the effect of Double Taxation Treaties (DTTs) on Spain’s inward and outward Foreign Direct … application by Spain of the territorial system is positively related to investment from this country to abroad. However, the tax … the investment of these countries into Spain. …
Persistent link: https://www.econbiz.de/10011983336