Qualitative case studies suggest that the outcomes of tax treaty negotiations are determined by power politics and negotiating capability. In contrast, quantitative studies have tended to depart from a model that implies absolute gains, full rationality, and perfect information on the part of...

Out of a total of 2,976 double tax agreements (DTAs), some 60% are signed between a developing and a developed economy. As DTAs shift taxing rights from capital importing to capital exporting countries, the prior would incur a loss. We demonstrate in a theoretical model that in a deal one...

The goal of this paper is to examine the methodology, used by authors Mackie-Mason and Gordon for measuring effects of corporate tax on business organization form, which is connected to issue of double taxation, in the United States and find out, if the same approach can be applied on business...

Pension policy reforms across the world in recent decades are a reaction to the changing demographic and socioeconomic environment. While pension scheme redesign has received much attention, the tax treatment of contributions, returns, and benefits of retirement savings remains mostly unattended...

There is a rising share of individuals spending at least some part of their working life abroad and acquiring pension rights. While the portability of pensions and other social benefits has received some analytical attention over the recent decade there is currently limited analytical guidance...

"Double Taxation and the League of Nations Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development...

Introduction -- Core International Tax Policy and Law -- Evasion and Avoidance According to the BRICS -- Countering Avoidance : SAARs -- Information Exchange -- Countering Treaty Benefits -- BEPS Final 2015 Reports -- Dispute Resolution -- BRICS and FDI : DTC Anti-abuse and Dispute Resolution --...

This book provides an overview of the taxation of income from services under double taxation conventions (DTCs) in major jurisdictions across the world. Especially due to the precipitous growth of the digital economy and thus the increased internationalization of services provisions, the...

This volume of the Cahiers has been published by Sdu, The Netherlands, on behalf of the International Fiscal Association (IFA). Once a year the Cahiers de Droit Fiscal International are published and distributed free to all the members of the Association.00These Cahiers contain a wealth of...

The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In this...

Introduction -- Tax treatment of inter-corporate cross-border dividends -- Interaction among diferent legal systems of international tax law -- Different dividend concepts in international tax law -- Dividend-distribution entities -- Dividend-stripping and the dividend-generating relationship --...