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IFA: The OECD Model Convention - 1998 & Beyond: The Concept of Beneficial Ownership in Tax Treaties
The OECD Model Tax Convention seminar is a regular feature of the annual IFA Congress. At the 1998 Congress, held in London, the seminar focused on the relationship between tax …
Tax Policy towards the National Heritage
IFA: Abusive Application of International Tax Agreements
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 …
IFA: Dividend Access Shares (Stapled Stock)
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 …
IFA: Secondary Adjustments and Related Aspects of Transfer Pricing Corrections
This seminar focused not only on the technical consideration of secondary aspects but also on the underlying philosophical question: namely, should secondary adjustments be …
IFA: Presumptive Income Taxation
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 …
IFA: Taxation Issues in a Federal State and Economic Groupings
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 …
IFA: The OECD Model Convention - 1997 and Beyond: Current Problems of the Permanent Establishment Definition
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 …
IFA: Environmental Taxes And Charges
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 …
IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: whether international law …
Taxation of domestic shareholders on underdistributed income of foreign corporate affiliates: objectives, techniques and consequences
IFA: Visions of the Tax Systems of the XXIst Century
In order to celebrate the fact that the Geneva Congress was the 50th IFA Congress, IFA arranged a Jubilee Symposium discussing the future long-term development of tax systems. In …