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The main goal of this seminar is to clarify on the basis of case studies what is meant by the concept of abusive application of tax treaties and whether and to what extent the …
A collection of conference papers on dividend access shares, a topic that relates mainly to cross-border mergers and acquisitions, but also to non-discrimination because most of …
This seminar focused not only on the technical consideration of secondary aspects but also on the underlying philosophical question: namely, should secondary adjustments be …
Presumptive taxation raises both theoretical and practical issues of great importance. From a policy perspective, the most interesting issue is probably to what extent presumptions …
One of the developments of the second half of the 20th century has been the formation of economic groupings to foster free trade among sovereign member states. These groupings fall …
This part of the IFA Seminar Series focuses on two aspects of the definition of permanent establishments: whether and when the provision of services may constitute a permanent …
This study analyzes the experiences that have occured with eco-taxes in existence or whose introduction is being planned. It includes different taxes/charges in use along with the …
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: whether international law …