1,721,060 research outputs found
Procedural Rules in Tax Law in the context of Community Law and Domestic Law, national report for Italy
No full textShipping, inland, waterways transport and air transport (article 8 OECD model convention)
No full textIn this contribution, shipping and air transport provisions found in the double taxation conventions are analysed and an historical overview is also provide
Chile
No full textThis chapter deals with the current landscape of tax treaty disputes for Chile. The authors examine tax dispute resolutions under a Mutual Agreement Procedure (MAP), as well as the experience with arbitration in international tax disputes. It delves in the new framework for arbitration in tax treaty matters including its main players (Arbitrators, Competent Authorities, Taxpayers and their Advisers), the arbitral procedure, method and decision. A comparison with investor-state dispute settlement mechanism and an outlook of the future of arbitration in tax matters is also provided
Chile
No full textBook Abstract: 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.
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. Tax academics and tax practitioners, along with investment law academics and practitioners, provided their input. A major focus is the attitude taken towards tax matters in the bilateral investment treaties of reporting countries, as is the relationship between double tax treaties and bilateral investment treaties. In addition to the national aspects, the book also outlines global trends and best practices, and in doing so it aims to analyse the consistency of existing policies with the international obligations undertaken in bilateral investment treaties. The general report elaborates extensively on issues connected with tax carve-out provisions in bilateral investment treaties and the arbitration of tax matters.
This book is of relevance to practitioners and academics working in tax law and international investment law, as well as students doing research and all who have an interest in the most current issues in these fields of law
LA SCALA A. E., EU-Taxes - Taxing competences within the legal framework of the European Community, national report for Italy, Kluwer International, Vienna, 2008
No full textAd oggi non esistono tributi "propri" dell'Unione europea. La loro imposizione solleva questioni tecniche di grande rilevanza e postula una spinta verso l'armonizzazione e il coordinaemnto delle politiche fiscali degli Stati membri. L'istituzione di tributi "comunitari" implicherebbe la nascita di un rapporto giuridico d'imposta tra contribuente e istituzioni comunitarie e dovrebbe avvenire senza innalzare l'attuare pressione fiscale all'interno degli Stati membri
Going Beyond Counting First Authors in Author Co-citation Analysis
Get PDFThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Variations on the Author
Get PDF“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
Get PDFWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
- …
