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The Relationship Between Taxation And Bilateral Investment Agreements Case Of The Slovak Republic


The Relationship Between Taxation And Bilateral Investment Agreements Case Of The Slovak Republic
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The Relationship Between Taxation And Bilateral Investment Agreements Case Of The Slovak Republic


The Relationship Between Taxation And Bilateral Investment Agreements Case Of The Slovak Republic
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Author : Jana Kubicova
language : en
Publisher:
Release Date : 2018

The Relationship Between Taxation And Bilateral Investment Agreements Case Of The Slovak Republic written by Jana Kubicova and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with categories.


One of the key characteristic features of the recent globalized world is cross-border investments. Due to this fact foreign investors and their investments in host countries need appropriate protection. Alongside with legal issues of protection of investors, another important issue arises too, namely necessity to eliminate double international taxation. Both issues, protection of foreign investors and investments plus elimination of double taxation, are covered by international, mostly bilateral treaties. This paper focuses on interaction between bilateral investment treaties and bilateral tax treaties, searching for potential overlap between them, and whether and how it is restricted. The paper is divided to the three sections, where first section focuses on the principles of treatment that are incorporated in the bilateral investment treaties. Second section puts under scrutiny detail relationship between bilateral investment treaties' clauses and taxation. Third section surveys dispute settlement according bilateral investment treaties established by Slovakia. Detailed study of relation between bilateral investment and bilateral tax treaty shows, that in case of those treaties established by Slovak republic there is no overlap between them.



The Impact Of Bilateral Investment Treaties On Taxation


The Impact Of Bilateral Investment Treaties On Taxation
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Author : Michael Lang
language : en
Publisher:
Release Date : 2017

The Impact Of Bilateral Investment Treaties On Taxation written by Michael Lang and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with categories.


The tax aspects of bilateral investment treaties, which, in most cases, provide the investor with the unique opportunity to directly initiate an international dispute settlement process? also known as investor-state dispute settlement? are often overlooked. The increasing number of tax-related investment disputes is a clear indicator of an urgent need to identify and examine the issues emerging in this area in an academic context.0 The aim of this book is to provide a comprehensive analysis of the relationship between taxation and bilateral investment treaties. Twenty-one national reports from countries across the globe have been compiled in this volume. The reports, prepared for the conference?The Impact of Bilateral Investment Treaties on Taxation?, which took place in Rust (Austria) from 2-4 July 2015, help bring to light tax aspects of bilateral investment treaties that have significant unexplored aspects.



The Role Of International Investment Agreements In Attracting Foreign Direct Investment To Developing Countries


The Role Of International Investment Agreements In Attracting Foreign Direct Investment To Developing Countries
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Author : United Nations
language : en
Publisher: Unctad Tl Investment Policies
Release Date : 2009

The Role Of International Investment Agreements In Attracting Foreign Direct Investment To Developing Countries written by United Nations and has been published by Unctad Tl Investment Policies this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Business & Economics categories.


Based on a study by Zbigniew Zimny (finalized by Hamed El-Kady, et al.), this paper reassesses the role of IIAs (bilateral treaties, etc.) as determinants of FDI, reviewing a number of econometric studies on their impact.



Bilateral Investment Treaties With The Czech And Slovak Federal Republic The Peoples Republic Of The Congo The Russian Federation Sri Lanka And Tunisia And Two Protocols To Treaties With Finland And Ireland


Bilateral Investment Treaties With The Czech And Slovak Federal Republic The Peoples Republic Of The Congo The Russian Federation Sri Lanka And Tunisia And Two Protocols To Treaties With Finland And Ireland
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Author : United States. Congress. Senate. Committee on Foreign Relations
language : en
Publisher:
Release Date : 1992

Bilateral Investment Treaties With The Czech And Slovak Federal Republic The Peoples Republic Of The Congo The Russian Federation Sri Lanka And Tunisia And Two Protocols To Treaties With Finland And Ireland written by United States. Congress. Senate. Committee on Foreign Relations and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992 with Government publications categories.




International Trade Investment And The Sustainable Development Goals


International Trade Investment And The Sustainable Development Goals
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Author : Cosimo Beverelli
language : en
Publisher: Cambridge University Press
Release Date : 2020-10

International Trade Investment And The Sustainable Development Goals written by Cosimo Beverelli and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-10 with Business & Economics categories.


A multi-disciplinary investigation of how economic globalization can help achieve the UN's 2030 Agenda, exploring trade-offs among the Goals.



U S International Investment Agreements


U S International Investment Agreements
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Author : Kenneth J. Vandevelde
language : en
Publisher: Oxford University Press
Release Date : 2009

U S International Investment Agreements written by Kenneth J. Vandevelde and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Business & Economics categories.


U.S. International Investment Agreements is the definitive interpretative guide to the United States' bilateral investment treaties (BITs) and free trade agreements (FTAs) with investment chapters. Providing an authoritative look at the development of the BIT program, treatment provisions, expropriation, and other provisions, Kenneth J. Vandevelde draws on his years of investment treaty and agreement expertise as both a former practitioner and a scholar. This unique and well-organized book analyzes the development of U.S. international investment agreement language and strategy within their historical context. It also explains the newest changes to the model negotiating text (US Model BIT 2004) and additional treaties.



Schwarz On Tax Treaties


Schwarz On Tax Treaties
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Author : Jonathan Schwarz
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-09-28

Schwarz On Tax Treaties written by Jonathan Schwarz and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-09-28 with Law categories.


Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.



The Effect Of Treaties On Foreign Direct Investment


The Effect Of Treaties On Foreign Direct Investment
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Author : Karl P Sauvant
language : en
Publisher: Oxford University Press
Release Date : 2009-03-27

The Effect Of Treaties On Foreign Direct Investment written by Karl P Sauvant and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009-03-27 with Law categories.


Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.



Bilateral Investment Treaties 1995 2006


Bilateral Investment Treaties 1995 2006
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Author :
language : en
Publisher: United Nations Publications
Release Date : 2007-01-01

Bilateral Investment Treaties 1995 2006 written by and has been published by United Nations Publications this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-01-01 with Business & Economics categories.


"The secretariat of the United Nations Conference on Trade and Development (UNCTAD) is implementing a programme on international investment arrangements. It monitors the trends in IIAs and analyzes the emerging issues and development implications. It seeks to help developing countries participate as effectively as possible in international investment rulemaking. ... This paper is part of the programme's research and policy analysis on international investment policies for development. ... The main objective of this paper is to update UNCTAD's 1998 study entitled Bilateral Investment Treaties in the Mid-1990s and to identify trends in the normative developments of each of the elements typically addressed in BITs since this last stocktaking in 1998. The study traces and explains the new issues that have emerged in recent BITs and also sets out the implications of those developments for developing countries."--Pref.



The Temporal Jurisdiction Of International Tribunals


The Temporal Jurisdiction Of International Tribunals
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Author : Nick Gallus
language : en
Publisher: Oxford University Press, USA
Release Date : 2017

The Temporal Jurisdiction Of International Tribunals written by Nick Gallus and has been published by Oxford University Press, USA this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Law categories.


The period of an international tribunal's temporal jurisdiction is the span of time during which an act must have occurred before the tribunal may consider if the act breached an obligation. There are many questions concerning this particular aspect of an international tribunal's jurisdiction: Does a tribunal have power over acts that occurred after the entry into force of the obligation allegedly breached, but before the tribunal's jurisdiction was accepted? What about acts that began before the tribunal's jurisdiction was accepted but continued after? To what extent can acts before the period of the tribunal's jurisdiction affect its decision on whether or not there is a breach through acts afterwards? The Temporal Jurisdiction of International Tribunals examines these questions in depth. Despite its importance, the temporal jurisdiction of international tribunals is not well understood. Tribunals often confuse different aspects of their jurisdiction and refuse to hear cases they should have heard, or agree to hear cases they should not. This book reduces this confusion by clarifying the different limits on the temporal jurisdiction of international tribunals and the important distinctions between those limits. The book examines the temporal limits resulting from (i) the entry into force of the obligation supposedly breached, (ii) the acceptance of the tribunal's jurisdiction, and (iii) from the period of limitation, as well as the effect of acts that occurred before these limits. Throughout the book, the author comprehensively compares decisions from a wide variety of sources, including the International Court of Justice, Human Rights Courts, World Trade Organization panels, and investment treaty tribunals. It comments on decisions that arose from some of the most notorious events of the twentieth century, including the "Katyn Massacre" of the Second World War, the 1994 Rwandan genocide, and the "forced disappearance" of American political opponents. It reviews these decisions and identifies common principles that help define the temporal jurisdiction of tribunals to decide breaches of international law. This book is essential for anyone practicing in international law, and anyone building a case that could be affected by temporal jurisdiction.