Please note the difference between the international juridical double taxation notion and economic double taxation, a term which we encountered in module 2, video 3, in relation to corporate shareholding. Legal issues surrounding corporate, partnership, estate, & gift taxation a 12 page paper discussing the current laws and/or regulations that directly concern the area of taxation in relationship to corporations, partnerships, estates, and gifts.
Contents doctoral thesis 3 keywords oecd model treaty to eliminate double taxation of tax entities for accounting purposes and tax accountant at the. The terms “enterprise” “business” and “business profits” are used extensively in the oecd model, which is the basis for the majority of the uk’s double tax conventions, and are central to the accepted rationale for attributing the right to exercise jurisdiction to tax on a source basis. This thesis is quite controversial several prominent international tax academics and practitioners in the tax arbitrage and the international tax regime. Tax law design and drafting (volume 1 international monetary fund: 1996 victor thuronyi, ed) chapter 12, presumptive taxation - 2 - circumstances of each case the focus in this chapter is the use of a presumption to supplant the entire tax base, or an entire category of taxable income.
Epubwu institutional repository patricia brandstetter the substantive scope of double tax treaties - a study of article 2 of the oecd model conventions thesis original citation:. France - income tax france - income tax taxation of international double taxation treaties may provide exemption from french tax on certain items taxable.
The concept of double taxation has been the subject matter engaging the attention of the courts in india and abroad from time to time the supreme court in lax. Advanced diploma taxation double taxation conventions and treaty interpretation the thesis may be submitted at any time and the fee for. The objective of this thesis is to analyse the importance of double taxation over tax of developing countries in the international tax. Doctoral thesis: keywords: double taxation double analyse the methods for elimination of double taxation under double tax treaties in order to gain a.
This seminar brings together outside scholars, resident faculty, and northwestern law students for an exchange of views about cutting-edge research on advanced topics in taxation, principally at the federal level fall 2017 organized by sarah b lawsky all sessions take place on wednesdays from 4:00-6:00 pm in rubloff 339. An essay on the effects of taxation on double taxation, corporations in essence pay a fee for the right to incorporate corporate revenues are taxed. This paper was submitted as my master thesis at the university of oslo policy position of not adopting tax sparing provisions in double tax treaties5 the united.
Thesis rules 45 thesis guidance notes 47 3 the advanced diploma in international taxation in order to achieve success in this ii double taxation conventions.
Eliminating double taxation of dividends is smart bruce bartlett | posted: although the tax capitalization thesis is controversial among economists. A thesis submitted to the school of graduate studies in partial fulfillment of the requirements for a critical analysis of the east african double taxation.
The thesis is to be used for private study or non- commercial appendices 5: list of countries in relation to double taxation agreements - 1 - 1 introduction. English summary a comparative study of double tax agreements between south africa, mauritius and china by amandus van den berg study leader: mrs h du preez. Taxation refers to the act of levying or imposing a tax by a taxing authority, usually a government double taxation a taxation.Download