Sökning: "Mariia Merkulova"

Hittade 1 uppsats innehållade orden Mariia Merkulova.

1. 1. Whether the domestic anti-abuse legislation applies to deny the tax treaty benefits

   Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

   Författare :Mariia Merkulova; [2013]
   Nyckelord :GAARs and double tax treaties; domestic anti-abuse legislation; Law and Political Science;

   Sammanfattning : The question raised in this thesis – whether the domestic anti-abuse legislation applies to deny the tax treaty benefits – cannot be decided unambiguously. As controversial debate shows, it is rather difficult to elaborate the uniform international approach concerning this issue due to a number of arguments: the incorporation of double tax treaties into domestic law takes place differently in various countries; some countries do not have GAAR at all, while others have well developed doctrines or an express statutory provision, or even the combination of both; also, some states explicitly define the relationship between the tax treaties and the GAAR, whilst others do not. LÄS MER