The authors, in this article, analyse the new
Netherlands–Switzerland Income Tax Treaty
(2010), compare it with the old Netherlands–
Switzerland Income and Capital Tax Treaty
(1951/1966) and the OECD Model (2008), and
provide insights regarding Swiss tax law and
related developments. Netherlands domestic
tax implications are generally not considered.
Key legislative and jurisprudential developments of Polish Antitrust Law in 2011Michal
The article presents key developments in Polish antitrust legislation and jurisprudence
of 2011. Its legislative part focuses on the renewal of Polish Group Exemption
Regulations for vertical agreements, specialization and R&D agreements as well as
cooperation agreements in the insurance sector. Noted is also the sole amendment
of the Competition Act introduced in 2011 which concerns the financial liability of
the Polish competition authority. The article covers also the new Guidelines of the
UOKiK President on the criteria and procedures of merger notifications. Presented
in its jurisprudential part is a number of 2011 rulings, mainly those rendered by
the Supreme Court and the Court of Appeals, divided according to their subject
matter with respect to particular types of restrictive practices and other problems
related to the decision-making process of the UOKiK President.
The Norwegian market offers great business opportunities for foreign enterprises within various areas.
The guide "Doing Business in Norway" provides an introduction to the legal aspects in Norway and answer key questions companies may have whilst establishing or developing business in Norway. The 2018 edition includes one new chapter on public procurement law.
Anti-Treaty Shopping: A Comparative Analysis of the U.S. and OECD Model Tax C...Akunobera
The presentation highlights the key approaches taken by the U.S. and the OECD to combat treaty shopping techniques and highlights key differences between those approaches.
[...] From 1919 to 1963, Belgium did not levy a uniform tax on total income. The income of individuals and corporations was taxed according to a schedular method based on its source.
[...]
Key legislative and jurisprudential developments of Polish Antitrust Law in 2011Michal
The article presents key developments in Polish antitrust legislation and jurisprudence
of 2011. Its legislative part focuses on the renewal of Polish Group Exemption
Regulations for vertical agreements, specialization and R&D agreements as well as
cooperation agreements in the insurance sector. Noted is also the sole amendment
of the Competition Act introduced in 2011 which concerns the financial liability of
the Polish competition authority. The article covers also the new Guidelines of the
UOKiK President on the criteria and procedures of merger notifications. Presented
in its jurisprudential part is a number of 2011 rulings, mainly those rendered by
the Supreme Court and the Court of Appeals, divided according to their subject
matter with respect to particular types of restrictive practices and other problems
related to the decision-making process of the UOKiK President.
The Norwegian market offers great business opportunities for foreign enterprises within various areas.
The guide "Doing Business in Norway" provides an introduction to the legal aspects in Norway and answer key questions companies may have whilst establishing or developing business in Norway. The 2018 edition includes one new chapter on public procurement law.
Anti-Treaty Shopping: A Comparative Analysis of the U.S. and OECD Model Tax C...Akunobera
The presentation highlights the key approaches taken by the U.S. and the OECD to combat treaty shopping techniques and highlights key differences between those approaches.
[...] From 1919 to 1963, Belgium did not levy a uniform tax on total income. The income of individuals and corporations was taxed according to a schedular method based on its source.
[...]
Bangladeshi money launderers have their money safeM S Siddiqui
Bangladesh has a bilateral double taxation avoidance treaty (DTAT) with the Switzerland only to avoid double taxation. It should ratify the multilateral Convention on Mutual Administrative Assistance in Tax Matters and sign the Automatic Exchange of Financial Account Information (MCAA) with Switzerland. It should also sign Foreign Account Tax Compliance Act (FATCA) agreement with the USA. It should amend the law and rule to support the protocol and agreements.
GATT (General Agreement on Tariff and Trade)Akshay Dhamija
GATT (General Agreement on Tariff and Trade)
Precursor organization to GATT, ITO, was first proposed in
February 1945 by the United Nations Economic and Social Council (UNESCO).
On 1 January 1948, the agreement was signed by 23 countries for the formation of GATT.
Total of 8 rounds was there, all are listed along with their respective year, venue and issues are mentioned in the sides.
ANALYSIS OF BREXIT IMPACT ON POLAND's MANUFACTURING INDUSTRYAlodia Fedora
EU has a long history with UK since UK was among the first countries that signed and joined the union yet due political, economical and social issues, Brexit referendum finally occurred. The term of Brexit refers to the withdrawal of UK from EU, it has caused tremendous uncertainties in different aspects of European Union. These uncertainties of post-Brexit provoke different assumptions and speculations about what will happen to European Union and to the rest of the members (i.e Poland). Poland, which is the biggest source of UK immigrants, might be directly influenced by Brexit both in positive and negative ways.
Therefore, this report will describe the EU history followed by the reasons and processes of Brexit. Furthermore, this report aims to analyse how the uncertainty of Brexit will impact on the EU, the Poland and Polish manufacturing industries.
The Dawn of a General Anti Avoidance Rule: the Italian ExperienceUniversity of Ferrara
Italy has recently introduced a GAAR in its tax system. While the wording of the clause is not original, considering the experience the other countries might have about it, it is the context in which the provision shall operate that arose the interest of the firs commentators.
The article considers is particular the ways in which it will be arguably applied, taking into account the similar (although tailor-made) regulations that address the phenomenon, and that that have not been repealed by it. Treaty based, EU inspired, special law enacted clauses are still there and may potentially collide with the GAAR, making the overall outcome unpredictable for the Interpreter and for the taxpayer as well.
"One Belt and One Road” Project" and the China-Italy Tax TreatyUniversity of Ferrara
Draft version of the slides used to open my lecure at the Cpital University of Business and Law, Beijing. I focused on the latest changes to the Italy - China DTC and the 2019 MoU signed in Rome.
MLI impact on DTAA between India and SwedenAnujShah116
I have tried to gauge impact of Multilateral Instrument (MLI) on Double Tax Avoidance Agreement (DTAA) between India and Kingdom of Sweden. Please find slides of the same for comments.
The United Kingdom’ s Diverted Profits Tax and Tax Treaties: An EvaluationRamon Tomazela
This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
Bangladeshi money launderers have their money safeM S Siddiqui
Bangladesh has a bilateral double taxation avoidance treaty (DTAT) with the Switzerland only to avoid double taxation. It should ratify the multilateral Convention on Mutual Administrative Assistance in Tax Matters and sign the Automatic Exchange of Financial Account Information (MCAA) with Switzerland. It should also sign Foreign Account Tax Compliance Act (FATCA) agreement with the USA. It should amend the law and rule to support the protocol and agreements.
GATT (General Agreement on Tariff and Trade)Akshay Dhamija
GATT (General Agreement on Tariff and Trade)
Precursor organization to GATT, ITO, was first proposed in
February 1945 by the United Nations Economic and Social Council (UNESCO).
On 1 January 1948, the agreement was signed by 23 countries for the formation of GATT.
Total of 8 rounds was there, all are listed along with their respective year, venue and issues are mentioned in the sides.
ANALYSIS OF BREXIT IMPACT ON POLAND's MANUFACTURING INDUSTRYAlodia Fedora
EU has a long history with UK since UK was among the first countries that signed and joined the union yet due political, economical and social issues, Brexit referendum finally occurred. The term of Brexit refers to the withdrawal of UK from EU, it has caused tremendous uncertainties in different aspects of European Union. These uncertainties of post-Brexit provoke different assumptions and speculations about what will happen to European Union and to the rest of the members (i.e Poland). Poland, which is the biggest source of UK immigrants, might be directly influenced by Brexit both in positive and negative ways.
Therefore, this report will describe the EU history followed by the reasons and processes of Brexit. Furthermore, this report aims to analyse how the uncertainty of Brexit will impact on the EU, the Poland and Polish manufacturing industries.
The Dawn of a General Anti Avoidance Rule: the Italian ExperienceUniversity of Ferrara
Italy has recently introduced a GAAR in its tax system. While the wording of the clause is not original, considering the experience the other countries might have about it, it is the context in which the provision shall operate that arose the interest of the firs commentators.
The article considers is particular the ways in which it will be arguably applied, taking into account the similar (although tailor-made) regulations that address the phenomenon, and that that have not been repealed by it. Treaty based, EU inspired, special law enacted clauses are still there and may potentially collide with the GAAR, making the overall outcome unpredictable for the Interpreter and for the taxpayer as well.
"One Belt and One Road” Project" and the China-Italy Tax TreatyUniversity of Ferrara
Draft version of the slides used to open my lecure at the Cpital University of Business and Law, Beijing. I focused on the latest changes to the Italy - China DTC and the 2019 MoU signed in Rome.
MLI impact on DTAA between India and SwedenAnujShah116
I have tried to gauge impact of Multilateral Instrument (MLI) on Double Tax Avoidance Agreement (DTAA) between India and Kingdom of Sweden. Please find slides of the same for comments.
The United Kingdom’ s Diverted Profits Tax and Tax Treaties: An EvaluationRamon Tomazela
This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
Tax 2012 Geneva: A precious tool, offering a clear and precise overview on taxes in Geneva. Translation into english under supervision of Eric Duvoisin.
Mise à jour sous la supervision d’Eric Duvoisin. Les informations dans cette brochure donnent un aperçu général de la fiscalité fédérale et genevoise. Elles sont destinées aux personnes ayant de bonnes connaissances du droit fiscal suisse et genevois et ont pour but de servir d’aide mémoire. Elles n’ont nullement la prétention d’être exhaustives et ne remplacent en rien les conseils d’un expert fiscal. Il s’agit de la situation de droit commun sans égard aux exceptions ou à une planification fiscale optimale.
Aperçu des nouveautés introduites par certains cantons dans le cadre de la ré...EricDuvoisin
Aperçu des nouveautés introduites par certains cantons dans le cadre de la révision de la législation fiscale (Fribourg, Genève, Jura, Neuchâtel, Vaud et Valais)
Mise à jour sous la supervision d\'Eric Duvoisin. Les informations dans cette brochure donnent un aperçu général de la fiscalité fédérale et genevoise. Elles sont destinées aux personnes ayant de bonnes connaissances du droit fiscal suisse et genevois et ont pour but de servir d’aide mémoire. Elles n’ont nullement la prétention d’être exhaustives et ne remplacent en rien les conseils d’un expert fiscal. Il s’agit de la situation de droit commun sans égard aux exceptions ou à une planification fiscale optimale.
Tax 2011 Geneva: A precious tool, offering a clear and precise overview on taxes in Geneva. Translation into english under supervision of Eric Duvoisin.