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LLM Theses and Essays

Taxation - International

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The Main Characteristics Of State's Jurisdiction To Tax In International Dimension, Alfred Nizamiev May 2003

The Main Characteristics Of State's Jurisdiction To Tax In International Dimension, Alfred Nizamiev

LLM Theses and Essays

This thesis analyzes the general characteristics of a state’s fiscal jurisdiction and how they influence the process of interaction with other national tax jurisdictions. The paper figures out essential internal substance of fiscal jurisdiction and its reflection on the necessity of interstate fiscal cooperation. After considering this substance the thesis goes on to explore the limits beyond which national jurisdictions cannot go in collection of taxes. Absence of common bases of these limits leads to conflicts between national jurisdictions and calls for close international fiscal cooperation. The thesis argues that the process of cooperation becomes more evident. In summary the …


Current Problems Of International Taxation Of Electronic Commerce, Nuran G. Kerimov May 2002

Current Problems Of International Taxation Of Electronic Commerce, Nuran G. Kerimov

LLM Theses and Essays

This thesis discusses the main problems that face tax authorities of many countries in the process of taxation of electronic commerce. It analyzes examples of problems posed by the growth of e-commerce in the context international direct and indirect taxation. Current international policy issues are the subject of discussion of the thesis. The thesis also analyzes some of the proposals regarding taxation of electronic commerce.


Transfer Pricing: A Comparative Study Of The French And U.S. Legal Systems, Valerie Ciancia Dec 2001

Transfer Pricing: A Comparative Study Of The French And U.S. Legal Systems, Valerie Ciancia

LLM Theses and Essays

For several decades, the number of multinational corporations has significantly increased and this phenomenon has created a new problem: the issue of transfer pricing. Indeed, national states have observed that multinationals could simply manipulate cross- border transfer pricing policies in order to shift profits from one jurisdiction to another. France, along with the United States, was one of the very first countries to introduce transfer-pricing legislations. Although the aims of the French and U.S. transfer pricing systems are similar, the means used to apply such rules are different and often raise difficulties to get rid of double taxations. Nevertheless, many …


David Vs. Goliath (2001): An Analysis Of The Oecd Harmful Tax Competition Policy, Truman Butler Dec 2001

David Vs. Goliath (2001): An Analysis Of The Oecd Harmful Tax Competition Policy, Truman Butler

LLM Theses and Essays

The OECD or Organization for Economic Cooperation and Development has produced a report titled Harmful Tax Competition An Emerging Global Issue. The report is the single largest threat to the offshore finance industry. Further, the sweeping recommendations made by the report would at worst potentially discourage foreign investment in some of the more established offshore financial centers. This thesis represents an analytical view of the report and further gives some highlights to the anomalies found in the tax regimes of the major industrialized countries. It is clear that the actions of the OECD does create in effect a tax cartel. …