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The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...
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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...
Persistent link: https://www.econbiz.de/10011334067
The Organization for Economic Cooperation and Development (OECD) under Base Erosion and Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements “result in a substantial erosion of the taxable bases of the countries concerned” and “have an overall...
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Sources of international (tax) law -- The relationship between national and international law -- Possible approaches to human rights and taxation -- General principles protecting taxpayers' rights -- Special features of human rights in taxation -- The procedural rights -- Taxpayers' rights...
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