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"Can't be nailed twice": avoiding double taxation by Canada and TaiwanLee, Emily Hsiang-hui 05 1900 (has links)
Canada and Taiwan have not entered into a tax treaty. Consequently, because each
jurisdiction uses different connecting factors, that is 'residence' in Canada and 'income
source' in Taiwan, double taxation may occur for individuals subject to tax in both
jurisdictions. With the increasing number of Taiwanese immigrants to and investors in
Canada, double taxation is becoming a significant problem. A treaty is probably the most
efficient mechanism to resolve the double taxation problem. However, the political issue
is how can a nation (Canada) enter into a treaty with a jurisdiction (Taiwan) that it does
not recognize as a nation state? Despite facing the same problem, on May 29, 1996
Australia signed a tax agreement with Taiwan concerning the avoidance of double taxation
and the prevention of tax evasion. The Australia-Taiwan Tax Agreement is unique
because it was signed by two private sector organizations rather than by the respective
governments. Using the same mechanism, New Zealand and Vietnam have signed tax
agreements with Taiwan as well. This thesis analyses the likelihood of Canada entering
into a tax treaty with Taiwan. In so doing, it considers how double taxation arises,
reviews the foreign reporting rules and argues that a tax treaty between Canada and
Taiwan is desirable.
The conclusion is that, theoretically and pragmatically, a tax treaty (or agreement)
between Canada and Taiwan is possible and needed in order to relieve punitive double
taxation and to facilitate bilateral economic and trading relations between the two
jurisdictions.
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Prospects for multilateral cooperation in taxationHadida, Jonathan. January 2006 (has links)
Globalization has placed a considerable strain on the current international tax structure predicated upon bilateral tax treaties. Multilateral cooperation may allow nation states to overcome many of globalization's effects. / The two prospects for multilateral cooperation are the creation of an international tax organization and a multilateral tax treaty to replace the current bilateral tax treaty network. Whereas there is currently no organization responsible for the surveillance of the international tax system, such an organization is within the realm of possibility. The perfect home for such an organization would be the OECD given its large expertise and history in taxation. However for political reasons it is difficult to foresee such scenario in the near future. / A more likely prospect is the creation of a series of multilateral tax treaties for economic regions. This is due to the fact that a multilateral tax treaty, as demonstrated by the Nordic Tax Convention, can be most successful within a group of nations that share close cooperation and highly integrated economies such as members of the EU or NAFTA already tied together through trade agreements.
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The taxation of income from foreign investments : a case study of some developing countries /Ong'wamuhana, Kibuta. January 1989 (has links) (PDF)
Thesis (LL. M)--University of Adelaide, 1991. / Submitted as Ph. D thesis. Includes bibliographical references (leaves 225-235).
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Cross-border consumption taxation of digital supplies : a comparative study of double taxation and unintentional non-taxation of B2C e-commerce /Rendahl, Pernilla, January 2008 (has links)
Diss. Jönköping : Internationella handelshögskolan, 2008.
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La prévention de la double imposition des bénéfices des sociétés par actions dans les rapports entre pays développés et pays en voie de développementImam, Ahmad Fahmy January 1974 (has links)
Doctorat en droit / info:eu-repo/semantics/nonPublished
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Taxing of dividends : a transition from secondary tax on companies (STC) to dividends taxTsoai, Elizabeth Tebogo 01 December 2012 (has links)
No abstract available. / Dissertation (LLM)--University of Pretoria, 2013. / Public Law / unrestricted
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"Can't be nailed twice": avoiding double taxation by Canada and TaiwanLee, Emily Hsiang-hui 05 1900 (has links)
Canada and Taiwan have not entered into a tax treaty. Consequently, because each
jurisdiction uses different connecting factors, that is 'residence' in Canada and 'income
source' in Taiwan, double taxation may occur for individuals subject to tax in both
jurisdictions. With the increasing number of Taiwanese immigrants to and investors in
Canada, double taxation is becoming a significant problem. A treaty is probably the most
efficient mechanism to resolve the double taxation problem. However, the political issue
is how can a nation (Canada) enter into a treaty with a jurisdiction (Taiwan) that it does
not recognize as a nation state? Despite facing the same problem, on May 29, 1996
Australia signed a tax agreement with Taiwan concerning the avoidance of double taxation
and the prevention of tax evasion. The Australia-Taiwan Tax Agreement is unique
because it was signed by two private sector organizations rather than by the respective
governments. Using the same mechanism, New Zealand and Vietnam have signed tax
agreements with Taiwan as well. This thesis analyses the likelihood of Canada entering
into a tax treaty with Taiwan. In so doing, it considers how double taxation arises,
reviews the foreign reporting rules and argues that a tax treaty between Canada and
Taiwan is desirable.
The conclusion is that, theoretically and pragmatically, a tax treaty (or agreement)
between Canada and Taiwan is possible and needed in order to relieve punitive double
taxation and to facilitate bilateral economic and trading relations between the two
jurisdictions. / Law, Peter A. Allard School of / Graduate
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A critical analysis of the taxation of income arising to contractors in relation to the execution of engineering, procurement, construction and installation (‘EPCI') contracts in the oil and gas sectorSmith, Shirlynn 25 February 2021 (has links)
Globally, the past two years have been successful years in oil and gas exploration with discoveries almost doubling those made in 2017.1 Notwithstanding Africa's endowment in vast natural resources, including substantial oil and gas reserves, one of the most dramatic finds in Africa has been Mozambique's natural gas developments. Mozambique is set to become one of the largest and most dominant natural gas finds in the world. These developments have attracted the attention from countries around the world, the UAE, in particular, taking the lead. Engineering, procurement, construction and installation (“EPCI”) contracts, are a common form of contract in the oil and gas sector, which is used to undertake large scale oil and gas projects. The nature of these contracts consists of significant local (in-country work) and foreign (out-of-country work) elements. Due to the complex nature of EPCI contracts, one of the major areas of dispute in the taxation environment are the uncertainties around the taxation of profits arising to contractors under these contracts. The taxpayer and the Revenue Authorities have different views as to where the income arising from EPCI contracts is to be taxed. The taxpayer takes the stand that only such income from the project as is relatable to activities in the host state, should be taxed in the host state. The Revenue Authorities contend that EPCI contracts are to be considered as one and indivisible, and hence the entire income from the contract is liable to be taxed in the host state. Based on an examination of recent judgments passed by the Authority of Advanced Rulings (“AAR”) and various Tax Courts, currently, there seems to be no certainty regarding the taxation of income arising to contractors under an EPCI contract and this has in turn resulted in a number of contractors having to pay excessive taxes. This dissertation seeks to analyse the tax treatment of income arising to contractors, from supplies and services under an EPCI contract in the context of the oil and gas sector entered into between Mozambique and the United Arab Emirates (“UAE”), in Mozambique. The purpose of this analysis is to determine how these profits should be taxed, in light of the Mozambique-UAE Treaty2 and Mozambican domestic legislation. In other words, the question that this dissertation seeks to answer is, whether profits arising from an EPCI contract in the oil and gas sector, should be taxed as a whole in Mozambique, or per the various components of the EPCI contract. 1 Fuel for thought, Africa oil and gas review, 2019, Current developments and a look into the future, www.pwc.co.za/oil-gas review [November 2019]. 2 Convention between the Republic of Mozambique and the Government of the United Arab Emirates for the Avoidance of Double Taxation with respect to Taxes on Income and Capital (2003). The key finding arising from the research presented in this dissertation is that although an EPCI contract is entered into in Mozambique (consisting of both offshore and onshore elements), this would not make the entire income from that contract to be taxable in Mozambique. Importantly, only such part of the income as is attributable to the operations carried out in Mozambique can be taxed in Mozambique. Following the analysis, as described above, this dissertation finally endeavors to provide recommendations on how contractors should approach and structure EPCI arrangements in order to create the best possible situation for themselves within the limits of what the law allows, and to reduce potential tax litigation. This can serve to inform other developing countries who have oil and gas operations.
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Prospects for multilateral cooperation in taxationHadida, Jonathan. January 2006 (has links)
No description available.
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Does Hong Kong need tax treaties?Rijntjes, Dick. January 1996 (has links)
published_or_final_version / Law / Master / Master of Laws
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