Relevant bibliographies by topics / Double taxation

Contents

  1. Journal articles
  2. Dissertations / Theses
  3. Books
  4. Book chapters
  5. Conference papers
  6. Reports

Academic literature on the topic 'Double taxation'

Author: Grafiati
Published: 4 June 2021
Last updated: 31 July 2024

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Journal articles on the topic "Double taxation"

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Arzu Jabbarov, Rahman. "INTERNATIONAL DOUBLE TAXATION: DSOUBLE TAXATION AGREEMENTS (DTA)." SCIENTIFIC WORK 65, no. 04 (April 23, 2021): 328–32. http://dx.doi.org/10.36719/2663-4619/65/328-332.

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As a result, present taxation, avoidance of double taxation and Double Taxation Agreements (DTA) are important elements of international trade relations. All states are interested in harmonizing tax systems to expand trade and other ties with each other. Thus, importance of double taxation agreements (DTA), structure of these treaties nneds to be resarched and stuidied in that article. Key words: taxation, history of double taxation, avoidance of double taxation, double taxation agreements, mechanics of double tax avoidance
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Ismer, Roland, and Julia Ruß. "What Is International Double Taxation?" Intertax 48, Issue 6/7 (June 1, 2020): 555–64. http://dx.doi.org/10.54648/taxi2020052.

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With the recent entry into force of the European Dispute Resolution Directive, the term international double taxation has gained legal relevance. This calls for revisiting the definition of international double taxation. This contribution presents the main approaches in the scholarly literature and demonstrates that the widely accepted definition of international double taxation is imprecise. Considering the function of tax treaties, it should instead be understood as a specific disadvantage to cross-border situations resulting from taxation by two or more states. Thus, neither discrimination by solely one state nor virtual double taxation constitute international double taxation in this context. The opposite is valid for intertemporal double taxation when new treaty rules must be created. The European Dispute Resolution Directive accords with the discrimination approach advocated here and substantiates the requirement of discrimination through three different variants. International double taxation, dispute resolution directive, juridical double taxation, economic double taxation, virtual double taxation, intertemporal double taxation, credit method, exemption method, single taxation, double non-taxation.
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Mehra, B. M. "International Double Taxation." Foreign Trade Review 22, no. 4 (January 1988): 452–97. http://dx.doi.org/10.1177/0015732515880406.

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Radu, Marius Eugen. "International Double Taxation." Procedia - Social and Behavioral Sciences 62 (October 2012): 403–7. http://dx.doi.org/10.1016/j.sbspro.2012.09.065.

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Oliver, J. David B. "Removing Economic Double Taxation." Intertax 31, Issue 4 (April 1, 2003): 130. http://dx.doi.org/10.54648/taxi2003030.

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Tiley, John. "Double Taxation—Visiting Academics." Cambridge Law Journal 49, no. 2 (July 1990): 225–28. http://dx.doi.org/10.1017/s0008197300117003.

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Mahmudlu, Shabnam. "ELIMINATION OF DOUBLE TAXATION." SCIENTIFIC WORK 17, no. 4 (April 19, 2023): 194–99. http://dx.doi.org/10.36719/2663-4619/89/194-199.

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Zhelekhovska, Tetiana. "Legal mechanism of avoiding double taxation in the European Union." Visegrad Journal on Human Rights, no. 4 (December 26, 2023): 103–10. http://dx.doi.org/10.61345/1339-7915.2023.4.18.

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The article titled “Legal Mechanism of Avoiding Double Taxation in the European Union” provides a comprehensive examination of the intricate legal framework established within the European Union (EU) to tackle the pervasive issue of double taxation. The contemporary landscape of the European Union is characterized by a dynamic and interconnected economic environment, fostering a thriving cross-border business ecosystem. However, this vitality often encounters significant impediments in the form of double taxation, where individuals or entities are subject to taxation in multiple EU member states for the same income or transaction. Double taxation not only creates administrative burdens but also undermines the seamless operation of the EU’s internal market. The article provides a comprehensive understanding of double taxation, delineating its various forms. It highlights the potential consequences of double taxation on businesses and individuals, such as reduced competitiveness, disincentives for foreign investment, and impediments to economic growth within the EU etc. Against this backdrop, the article delves into the central theme of the legal mechanisms implemented by the European Union to combat double taxation. It recognizes that while taxation is primarily within the purview of individual member states, the EU has intervened with a series of directives, treaties, and judicial rulings to harmonize and streamline tax practices. The article “Legal Mechanism of Avoiding Double Taxation in the European Union” explores the complex and crucial issue of double taxation within the EU. It delves into the various legal instruments, directives, and tax treaties that have been established to prevent or mitigate double taxation, which can arise when individuals or businesses are subject to taxation in multiple EU member states. The article provides insights into key EU directives, bilateral tax treaties, European Court of Justice practice etc.
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Karuna, Vikram. "International double taxation: Interpretation in the Indian context and general mitigation Measures." Journal of Management Research and Analysis 11, no. 1 (March 15, 2024): 41–45. http://dx.doi.org/10.18231/j.jmra.2024.008.

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International Double Taxation poses a complex challenge with diverse interpretations, especially in the Indian context. This paper investigates the nuances of double taxation, focusing on legal principles, double taxation avoidance agreements (DTAAs), and their implications for residents and permanent establishments. It analyzes India's engagement in double taxation treaties, considering monistic and dualistic principles, legislative processes, and recent judicial developments. Case studies from French and Indian courts offer insights into treaty interpretation. The paper examines relief methods such as Exemption, Credit, Tax-sparing, and Expense Deduction, emphasizing their application within Indian tax treaties. Notably, Permanent Establishment (PE) significance in international taxation is explored through relevant case law. Conclusively, the paper underscores the importance of addressing international double taxation in the globalized era. It argues that while various relief methods exist, the Exemption method is most effective in mitigating double taxation, contrasting with the partial relief provided by the Credit method. The choice of relief method varies across nations based on financial considerations. This comprehensive exploration contributes to understanding international double taxation in the Indian context, highlighting legal interpretations, treaty dynamics, and mitigation measures. It advocates for harmonizing global approaches to achieve more effective and equitable solutions in international taxation.
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Latkovska, Tamara, Pavlo Latkovskyi, and Anastasiia Podolska. "Legal ways of double taxation resolving." Revista Amazonia Investiga 9, no. 26 (February 21, 2020): 365–71. http://dx.doi.org/10.34069/ai/2020.26.02.42.

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The purpose of the article is a comprehensive study of the problems of double taxation, which is at the intersection of categories of taxable entity and taxpayer. According to the purpose, it is substantiated that double taxation arises in the case of taxation of income received by residents abroad, or in the case of a mixed procedure of tax payment, or in the taxation of the distributed part of the profits of enterprises. It has been established that double taxation is also possible with the partial imposition of one object on another, and this can occur both within the same country and under different tax systems. The taxation of petroleum products with excise tax, which resulted from the legislative regulation that led to double taxation, was considered and analyzed. In the process of researching the topic of the article, the authors conclude that, starting from 2016, the legislator actually introduced double taxation with the same tax and accordingly replaced the ad valorem excise tax rate on retail sales of excisable goods with specific ones (Euro tax rate per unit of tax). It is stated that double taxation of one and the same taxpayer is a violation of Article 1 of the Protocol to the Convention for the Protection of Human Rights and Fundamental Freedoms of each natural or legal person, the right to peacefully own their property.
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Dissertations / Theses on the topic "Double taxation"

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Rijntjes, Dick. "Does Hong Kong need tax treaties?" Thesis, Click to view the E-thesis via HKUTO, 1996. http://sunzi.lib.hku.hk/HKUTO/record/B3862784X.

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López, Nieto Sebastián. "The Non-Discrimination Clause in Double Taxation Agreements." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/118516.

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This article analyzes the scope of the non-discrimination rule contained in Double Taxation Avoidance Treaties, especially those signed by Argentina. This document considers the OECD and the ILADT Models, which contain provisions designed to ensure that Contracting States do not give any preferential treatment in taxing its own residents or citizens as opposed to the treatment granted to non-residents. Additionally, it analyzes the recent jurisprudence in the Argentine Courts.
En el artículo se analiza el concepto y alcance del principio de “no discriminación” contenido en los Convenios para evitar la Doble Imposición, con especial énfasis en aquellos suscriptos por la República Argentina. Se analizan los Modelos de Convenio OCDE e ILADT, los cuales contienen provisiones diseñadas para prevenir que un Estado contratante otorgue a sus residentes o nacionales un tratamiento impositivo preferencial en relación al otorgado a los no residentes. Adicionalmente, se analiza la reciente jurisprudencia de los tribunales argentinos aplicable en la materia.
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Rendahl, Pernilla. "Cross-border consumption taxation of digital supplies : a comparative study of double taxation and unintentional non-taxation of B2C e-commerce /." Jönköping : Jönköping International Business School, Jönköping University, 2008. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-6603.

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Hagena, Antje. "Die Behandlung von Personengesellschaften in den Doppelbesteuerungsabkommen der Bundesrepublik Deutschland mit den Staaten Mittel- und Südamerikas /." Frankfurt am Main [u.a.] : Lang, 2006. http://www.gbv.de/dms/spk/sbb/recht/toc/51951405X.pdf.

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Hjipanayi, Christiana. "Double taxation, tax treaties, treaty shopping and the European Community." Thesis, London School of Economics and Political Science (University of London), 2006. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.440460.

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Soler, Roch María Teresa. "The Taxation of Capital Gains in Double Tax Convention Models." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/118674.

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The article deals with the taxation of capital gains in cross-border situations, according to the relevant provision in the different Model Conventions (OECD, UN, and US). Following an introduction to the topic, the article analyzes the concept of capital gains, as well as the allocation rules applicable to gains derived from the alienation of different type of assets, including specific anti-abuse provisions and a final reference to the exit taxes.
El artículo trata de la tributación de las ganancias de capital en situaciones transfronterizas, de acuerdo con las disposiciones previstas en los distintos Modelos de Convenio (OCDE, ONU y EEUU). Tras una introducción al tema, el artículo analiza el concepto de ganancias de capital, así como las reglas de atribución aplicables a las ganancias obtenidas en la transmisión de distintos tipos de bienes, incluyendo cláusulas anti-abuso específicas y una referencia final a los impuestos de salida.
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Espinosa, Sepúlveda Jorge. "Latin American income tax systems and current double taxation agreements." Pontificia Universidad Católica del Perú, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/115595.

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Tax systems in Latin America have played a very important role as the main, and in some cases the only, means of obtaining revenue to finance the major public expenditure that is necessary for the work of the states through time. Below is a short review of the main aspects of tax systems in the región, with emphasis on the impact of taxes on income in force in the majorLatin American countries, as well as a brief explanation of the network of agreements to avoid double taxation that are in force in each of them.
Los sistemas tributarios en América Latina han jugado un rol muy importante como los principales, y en algunos casos los únicos, medios de obtención de ingresos públicos para financiar los ingentes gastos públicos necesarios para el quehacer de los estados a través de los tiempos. A continuación se presenta una pequeña reseña de los principales aspectos delos sistemas tributarios en la región, con énfasis en el impacto de los impuestos a la renta vigentes en los principales países de América Latina. Asimismo, se incluye una breve explicación de la red de convenios para evitar la doble imposición, vigentes en cada uno de dichos países.
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Jogarajan, Sunita. "Double Taxation and the League of Nations in the 1920s." Thesis, The University of Sydney, 2016. http://hdl.handle.net/2123/15765.

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This thesis considers the development of the first model tax treaties by the League of Nations in the 1920s based on archival research in the League's archives in Geneva, and also in other archives in the UK and the US. The thesis shows that once the first resolutions were agreed by a small committee in 1925, the enlarged committee constituted for meetings in 1927 and 1928 was unwilling to reopen the earlier agreement reached. As a result some common assertions in the literature are found to be incorrect: the International Chamber of Commerce and the US delegate TS Adams had little impact on the development of the League's models, and the UK and US did not operate in concert to push a developed country bias in the development of the model treaties. More generally the thesis finds that common assertions about the history of tax treaties in the League of Nations in the current debates over taxation of multinationals are incorrect.
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Hadida, Jonathan. "Prospects for multilateral cooperation in taxation." Thesis, McGill University, 2006. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=101818.

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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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Tadmore, Niv, and mikewood@deakin edu au. "The interaction between tax treaties and e-commerce re-examined." Deakin University. School of Law, 2003. http://tux.lib.deakin.edu.au./adt-VDU/public/adt-VDU20050719.085242.

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Books on the topic "Double taxation"

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Reid, P. A. Double Taxation Relief. London: Institute of Chartered Accountants in England andWales, 1986.

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Organisation for Economic Co-operation and Development, ed. International double taxation. Alphen aan den Rijn: Kluwer Law International, 2011.

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Taylor, Rodney B. Double taxation relief. 2nd ed. Croydon: Tolley, 1996.

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Reid, Alan. Double taxation relief. London: Member Services Directorate of The Institute of Chartered Accountants in England and Wales, 1989.

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Philip, Baker. Double taxation agreements. London: Key Haven, 1990.

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Haccius, Charles. Double taxation agreements. Dublin: Institute of Taxation in Ireland, 1998.

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Newns, Ralph. Double taxation relief for shipping. London: Lloyd's of London Press, 1988.

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Walker, Francis. Double taxation in the United States. Clark, N.J: Lawbook Exchange, 2003.

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Cabantac, Gregorio V. International tax treaty practices and rulings: The RP-US Tax Treaty. Manila, Philippines: Published & distributed by Rex Book Store, 2009.

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Cabantac, Gregorio V. International tax treaty practices and rulings: The RP-US Tax Treaty. Manila, Philippines: Published & distributed by Rex Book Store, 2009.

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Book chapters on the topic "Double taxation"

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Sarmento, Joaquim Miranda. "International Double Taxation." In Springer Texts in Business and Economics, 245–51. Cham: Springer International Publishing, 2023. http://dx.doi.org/10.1007/978-3-031-22097-5_10.

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Shome, Parthasarathi. "Double Taxation Avoidance Agreements." In Taxation History, Theory, Law and Administration, 321–28. Cham: Springer International Publishing, 2021. http://dx.doi.org/10.1007/978-3-030-68214-9_27.

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Rixen, Thomas. "Eradicating the ‘Evils of Double Taxation’." In The Political Economy of International Tax Governance, 86–116. London: Palgrave Macmillan UK, 2008. http://dx.doi.org/10.1057/9780230582651_5.

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Phillips, John S. "Methods for Elimination of Double Taxation." In Tax Treaty Networks 1991, 725–79. London: Routledge, 2021. http://dx.doi.org/10.4324/9781315075631-24.

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Rakovský, Peter. "The Arbitration Convention as One of the Measures to Eliminate Double Taxation... in the European Union and in Slovak Republic." In Cofola International 2021, 440–55. Brno: Masaryk University Press, 2021. http://dx.doi.org/10.5817/cz.muni.p210-8639-2021-17.

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In the world of taxes, double taxation or double non-taxation represents one of the main problems within international taxation. Fair taxation, which manifests itself as a taxation of incomes in countries where the value is created in the light of legal tax optimization, is an important issue for a lot of international organisations and a relevant topic of innumerable initiatives and statements. In that regard, tax disputes between two or more states arise whose subject is the profit allocation. Such dis-putes are the main object of the so-called Arbitration Convention, which stipulates international chall-enge of the present and future of the profit allocation. Secondary subject of this article is to point out other relevant international and national arbitration measures within the European Union and Slovak Republic.
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Rixen, Thomas. "Institutional Choice in the Avoidance of Double Taxation." In The Political Economy of International Tax Governance, 155–80. London: Palgrave Macmillan UK, 2008. http://dx.doi.org/10.1057/9780230582651_7.

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Sabharwal, Manuj. "International Double-Taxation Avoidance Law and Indian Practice." In Indian Practice of International Law, 260–80. London: Routledge India, 2024. http://dx.doi.org/10.4324/9781003366331-19.

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Tsenes, Christos K., and Dimitrios D. Thomakos. "The Double Trap: Taxes and Subsidies as Determinants of Economic Growth and the End of the Downward Growth Spiral in Greece." In Taxation in Crisis, 359–87. Cham: Springer International Publishing, 2017. http://dx.doi.org/10.1007/978-3-319-65310-5_14.

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Yang, Harry, Dermot Cahill, and Edwin T. Hood. "Corporate Profits’ Tax Avoidance: How the “Double Irish” Impedes Global Social Progress and Removes the Prosperity Base Needed for Future Generations." In Taxation in Crisis, 103–18. Cham: Springer International Publishing, 2017. http://dx.doi.org/10.1007/978-3-319-65310-5_5.

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Haslehner, Werner. "Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law." In State Aid Law and Business Taxation, 133–61. Berlin, Heidelberg: Springer Berlin Heidelberg, 2016. http://dx.doi.org/10.1007/978-3-662-53055-9_8.

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Conference papers on the topic "Double taxation"

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Erdős, Éva, and Lilla Nóra Kiss. "Double Taxation and Double Non-Taxation as the New Tendencies of EU e-Tax Law." In MultiScience - XXXIII. microCAD International Multidisciplinary Scientific Conference. University of Miskolc, 2019. http://dx.doi.org/10.26649/musci.2019.037.

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Armeanic, Alexandru. "Scope Of International Treaties To Avoid Double Taxation." In 27th International Scientific Conference “Competitiveness and Innovation in the Knowledge Economy”. Academy of Economic Studies of Moldova, 2024. http://dx.doi.org/10.53486/cike2023.61.

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The conventions concluded by the Republic of Moldova on the notion of "person" do not include the element of society, replacing it with the notion of a legal entity. Data: However, the conventions concluded by the Republic of Moldova in the article that will refer to the general definitions (art. 3), will not even refer to the content of a legal person, as is done in the case of the Model Convention, when it refers to the notion of "society". Methodology: These distinctions do not have deviant interpretations, because the notion of "company" is defined by the Model Convention in the following way: "the term "company" designates any legal person or any entity that is considered for taxation purposes as a legal person". Findings: Therefore, in the broad sense of the concept of "legal person", used in the conventions concluded by the Republic of Moldova, only those legal persons that are taken into account "for the purpose of taxation" can be defined, i.e. legal persons that are subject to taxation with regard to taxes which are covered by the convention. In the case of legal entities, when it is a resident of both contracting states, it is considered resident in that contracting state where the effective management body is located. It is necessary to underline the fact that the international benefits of elimination of double taxation are offered only to subjects resident in one or both signatory states. A taxable subject who is not resident in one of these states will not be able to benefit from the provisions of the conventions.
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Larisa, Aslanbekovna. "Double Taxation: Concept, Causes And Procedure For Elimination." In International Scientific Conference «Social and Cultural Transformations in the Context of Modern Globalism» dedicated to the 80th anniversary of Turkayev Hassan Vakhitovich. European Publisher, 2020. http://dx.doi.org/10.15405/epsbs.2020.10.05.170.

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McCarthy, J. R. "Avoiding International Double Taxation in the Petroleum Industry Since 1969." In Symposium on Energy, Finance, and Taxation Policies. Society of Petroleum Engineers, 1986. http://dx.doi.org/10.2118/14646-ms.

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Filipova-Slancheva, A. "Bulgarian Double Taxation Approach and the Role of Accountants." In The 4th Human and Social Sciences at the Common Conference. Publishing Society, 2016. http://dx.doi.org/10.18638/hassacc.2016.4.1.199.

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Baliyan, Parthik, Bhawna Arora, and Kavita. "TaxBot: An AI-driven Chatbot for Resolving Double Taxation Queries in India." In 2024 IEEE 1st Karachi Section Humanitarian Technology Conference (KHI-HTC). IEEE, 2024. http://dx.doi.org/10.1109/khi-htc60760.2024.10481983.

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Liu, Ye, Lin-yu Qiu, and Zhi-bo Zhou. "An empirical study on “double dividend” in China's existing environmental taxation." In 2009 International Conference on Management Science and Engineering (ICMSE). IEEE, 2009. http://dx.doi.org/10.1109/icmse.2009.5317625.

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Nan Li and Yunlan Chen. "Elimination of international double taxation in connection with the adjustment of transfer pricing." In 2010 Second International Conference on Communication Systems, Networks and Applications (ICCSNA). IEEE, 2010. http://dx.doi.org/10.1109/iccsna.2010.5588909.

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Dulevski, Stoycho. "SOME ASPECTS REGARDING THE TIME CRITERION IN THE OECD-MC." In THE LAW AND THE BUSINESS IN THE CONTEMPORARY SOCIETY 2020. University publishing house "Science and Economics", University of Economics - Varna, 2020. http://dx.doi.org/10.36997/lbcs2020.241.

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The Double Tax Treaties (DTTs) are an important regulator in international taxation. Their provisions outline the prerequisites, which implementation determines their proper application. It is noteworthy that time criterion is derived in some of them. This necessitates their examination both from theoretical and practical perspective.
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Protsenko, Iryna. "LEGAL STATUS AND PECULIARITIES OF TAXATION OF E-RESIDENTS IN UKRAINE." In Innovative Solutions for Managing the Economy in an International Crisis Scenario. Oikos Institute – Research Center, Bijeljina, Bosnia and Herzegovina, 2023. http://dx.doi.org/10.61432/cpne0101244p.

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Even in times of war, Ukraine is introducing new, unconventional ways of doing business. The article will deal with one of them, namely doing business in Ukraine without the physical presence of the entrepreneur, i. e. by a socalled e-resident. The Ukrainian government expects to attract a wider range of foreign entrepreneurs in this way. First of all, foreign IT-specialists may act in this capacity. Certainly, such a way of doing business is best suited to such crisis stages in the state’s history as an armed conflict or a pandemic. The legal regulation of the status and peculiarities of taxation of e-residents appeared in Ukrainian legislation only at the end of 2022, so the practice of its application is small and certainly may cause some problems, for example in the area of double taxation. However, the results of the study of the specifics of legal regulation of these aspects in Ukraine may provide a basis for understanding new approaches that can be used for the international organisation of work of small entrepreneurs, who are the most affected by economic crises.
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Reports on the topic "Double taxation"

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Goulder, Lawrence. Environmental Taxation and the "Double Dividend:" A Reader's Guide. Cambridge, MA: National Bureau of Economic Research, October 1994. http://dx.doi.org/10.3386/w4896.

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Lorenz, Johannes, Caren Sureth-Sloane, and Markus Diller. Inconsistent tax transfer prices: tax filings, audits, and double taxation. TRR 266 Accounting for Transparency, 2021. http://dx.doi.org/10.52569/acpj5634.

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Boustati, Alma. The Advantages and Disadvantage of Double Taxation Agreements for Developing Countries. Institute of Development Studies, September 2022. http://dx.doi.org/10.19088/k4d.2022.143.

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When a developing and a developed country sign Double Taxation Agreements (DTAs), its generally the case that the developing country is the one that forgoes some of its tax revenues (Braun & Fuentes, 2016). Nevertheless, developing countries enter these agreements on the assumption that this will have enough economic benefits to offset these losses (Neumayer, 2007). Besides alleviating the burden of double taxation, DTAs also have the added value of improving exchange of information, which helps combat tax evasion and avoidance (Barthel et al., 2009). One of the incentives for signing DTAs for developing countries is the increase in Foreign Direct Investments (FDIs) (Neumayer, 2007). The evidence from the literature on the link between signing DTAs and increasing FDIs is very mixed, with some finding a positive impact and others finding no impact (Quak & Timmis, 2018). However, the literature points to some clear factors that drive the relationship between FDIs and DTAs. There are also studies that attempt to quantify the tax revenue loss of developing countries when they enter DTAs. All the studies find substantial negative loss, although most do not account for the potential benefit of increased FDIs (ActionAid, 2016; IMF, 2014; Janský & Šedivý, 2018; McGauran, 2013; Van de Poel, 2016). There are also other reasons for why developing countries may still commit to negotiate and enter DTAs even when the benefits are not guaranteed. This includes increasing diplomatic ties with the treaty partner and the incentive of receiving foreign aid (Braun and Zagler, 2017). The other is a prisoner’s dilemma situation. The two most prevalent DTA conventions are the OECD Model and the UN Model. The UN Model tends to be more advantageous for developing countries compared to the OECD Model (Eyitayo-Oyesode, 2020). There are many issues over which the UN Committee’s expert members from developed and developing countries disagree but developed country member are better at influencing decisions. Finally, the OECD Model is updated more frequently, resulting in the UN one being comparatively out of date (Hearson, 2015; Quak & Timmis, 2018). Generally, the literature on the impact of DTAs on developing countries’ economies is extensive. This is especially the case for the impact of DTAs on FDIs as well as on tax revenue loss. However, because of the complexity of these issues, many of the empirical studies inevitably suffer from methodological issues that make conclusive claims very difficult. Notably missing from the literature is the impact of DTAs on international trade.
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4

Morck, Randall. Why Some Double Taxation Might Make Sense: The Special Case of Inter-corporate Dividends. Cambridge, MA: National Bureau of Economic Research, April 2003. http://dx.doi.org/10.3386/w9651.

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5

Kinda, Harouna, and Abrams M. E. Tagem. Double taxation treaties and resource revenue mobilization in developing countries: A neural network approach. UNU-WIDER, October 2023. http://dx.doi.org/10.35188/unu-wider/2023/433-5.

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6

Cantens, Thomas, and Gaël Raballand. Taxation and Customs Reforms in Fragile States: Between Bargaining and Enforcement. Institute of Development Studies (IDS), May 2021. http://dx.doi.org/10.19088/ictd.2021.009.

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In the last decade, African authorities and the international community have called for support to increase taxation capacity in order to reduce reliance on aid flows. This commitment to support tax administrations was reflected in the 2015 Addis Tax Initiative (ATI), which advocated ‘to double assistance to developing countries in order to strengthen their tax systems and administrations’ by the year 2020 (IMF 2017: 6). Increasing domestic resource mobilisation is even more salient for state-building in fragile states, in terms of providing costly services to citizens, including security, across national territory. There is a rich literature (Acemoglu and Robinson 2012; Besley and Persson 2009) arguing that robust and inclusive fiscal institutions are essential for state-building and economic growth. This is not the situation in fragile states.
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7

Trachtenberg, Danielle. Tax Barriers to Services Imports in Latin America and the Caribbean: The Case of IT Services. Inter-American Development Bank, October 2022. http://dx.doi.org/10.18235/0004511.

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This document uses responses from a questionnaire to examine whether tax policy is a barrier to information technology (IT) services imports in Latin America and the Caribbean. The responses show that existing policies do not create a level playing field in the upfront tax burdens paid on transactions, although whether domestic or imported IT services face lower burdens varies by country. The responses also underline that the issue of taxation of services is primarily taken up in double taxation treaties rather than preferential trade agreements, suggesting that trade agreements do not ensure equitable treatment between domestic and imported services as effectively for services as for goods.
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Akua Anyidoho, Nana, Max Gallien, Mike Rogan, and Vanessa van den Boogaard. Mobile Money Taxation and Informal Workers: Evidence from Ghana’s E-Levy. Institute of Development Studies, September 2022. http://dx.doi.org/10.19088/ictd.2022.012.

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The use of digital financial services, including money transfers and mobile money, have expanded widely in lower-income countries in the past decade; 47 per cent of the population of sub-Saharan Africa (548 million) had a registered mobile money account in 2020, with 29 per cent of those accounts representing active users (Andersson-Manjang and Naghavi 2021: 8). Among lower-income countries for which data is available, the average number of mobile money accounts is more than double the number of commercial bank accounts. In many lower-middle-income countries, mobile money usage is the same or more than commercial bank usage (Bazarbash et al. 2020). Alongside this growth, governments have increasingly sought to tax DFS, rooted in deeper discussions about the role that technology can play in increasing tax revenue and strengthening overall state capacity (Fan et al. 2020; Okunogbe and Santoro 2021). While capturing revenue from DFS can come from many sources, mobile money taxes in particular have often been introduced due to the untapped revenue potential and the relatively convenient and easy nature of the tax handle (Lees and Akol 2021a) – particularly in relation to, say, corporate income taxes on financial service providers. As noted above, the search for revenue is often closely linked to a desire to capture revenue from workers in the informal economy, who are often framed as tax evaders.
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9

Morck, Randall. How to Eliminate Pyramidal Business Groups - The Double Taxation of Inter-Corporate Dividends and Other Incisive Uses of Tax Policy. Cambridge, MA: National Bureau of Economic Research, December 2004. http://dx.doi.org/10.3386/w10944.

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10

Shehaj, Pranvera, and Martin Zagler. Asymmetric Double Tax Treaties and FDI in Developing Countries: The Role of the Relief Method and Tax Sparing. Institute of Development Studies, March 2023. http://dx.doi.org/10.19088/ictd.2023.009.

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This study focuses on asymmetric tax treaties and investigates the impact of OECD member states’ double tax relief method and of treaty tax sparing provisions on investments in developing countries, while considering network effects. In addition, it analyses the impact of a residence country’s tax relief method on the source country’s tax policy. Our results suggest that having a treaty between the OECD member state and the developing country, which improves the investor’s conditions in terms of tax burden by changing the unilateral tax relief method, increases FDI to the developing country. The positive effect prevails when investigated within investments made through the direct route from home to host. Furthermore, results suggest that OECD member states offer tax sparing provisions mostly to less-developed economies, which already receive very low, if any, foreign direct investment. Finally, we find that developing countries set higher corporate income tax (CIT) when the OECD member state relieves double taxation through the exemption method, as compared to when it offers a foreign tax credit, while the inclusion of tax sparing agreements has a positive effect on the CIT.
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