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Gradually, taxpayers have become increasingly responsible for their own pensions. One of the reasons for this development is related to the problems Member States have had in financing their retirement systems. This has made second and third-pillar provisions increasingly important. Therefore it...
In the light of the much-discussed BEPS report, the OECD proposes to implement more effective anti-avoidance measures to be included in international instruments. Limitations on Benefits (LOB) rules are mentioned as one of the possible anti-treaty abuse rules. The compatibility of these clauses...
This article deals with the substantial economic activity criterion as defined in the Code of Conduct for Business Taxation, in the Organisation for Economic Co-operation and Development (OECD) Report Harmful Tax Competition - An Emerging Global Issue and, more recently, in the item 5 of Base...
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