Tax Treaties Between Belt and Road Countries
This chapter follows the structure of the OECD (2014) and UN Model Tax Conventions (2011) and compares the respective provision of these Models and the above-mentioned tax treaties. Although covering the vast majority of Belt and Road countries, the authors recognize that there are differences in the scope of Belt and Road countries and, accordingly, some countries might be missing. Thus, the authors’ selection constitutes a representative portion. At a future stage, the authors will perform a similar analysis of the remaining treaties between key Belt and Road countries.
The range of the subjects for study and research available to law students at universities and law schools has been extended over the recent years. To large extent, those newly in troduced disciplines and areas of learning cover a relatively limited scope of subjects which are related to the major, "foundation" courses. However, a development of the professional orientation in the study of law and legal research, as well as a shift towards a new frameworkof professional law education also require diversification of specific subjects. Therefore, the purpose of this article is to outline the International TaxLaw course and its potential as a separate discipline for study and research.
международное налоговое право, международное налогообложение, предмет и методы науки, ЮРИСПРУДЕНЦИЯ, International TaxLaw, international taxation, subject matter and methods of research, legal studies
This chapter addresses several transfer pricing topics by providing, first, a background on each one, taking into account the main features from a general international perspective as well as those specifically related to OBOR countries, and, then, some conclusions and proposal for future developments.
General anti-avoidance rules (GAARs) have been a topic of great relevance in practice as well as in academia for decades. In a post-BEPS tax world, with national legislators introducing or tightening GAARs, and with the European Union and OECD suggesting the implementation of such rules, the topic seems more important than ever. The aim of this book is to give tax policymakers, tax authorities, tax courts and tax practitioners an idea of the various understandings of and approaches towards tax avoidance in 39 countries. In order to do so, 39 national reports from countries across the globe have been compiled and are published in this volume. More than 100 experts, including the authors of the national reports, convened for a joint conference on “General Anti-Avoidance Rules (GAARs) – A Key Element of Tax Systems in the Post-BEPS Tax World?” in Rust, Austria, from 3-5 July 2014. The national reports focus on the requirements for the application of GAARs and on the legal consequences of applying a GAAR. Moreover, the relationship between GAARs and SAARs, as well as tax treaties and EU law requirements, are given much attention. A further objective of this book is to shed light on recent European developments and on alternatives to GAARs.
The main focus of the research is "one belt and one road" intitiative and its role in public diplomacy of China.
The authors provide an article-by-article overview of the double tax treaty Russia-Argentina effective as of January 1, 2013.
Since the global financial crisis of 2007–2009 all Asian powers (both rising and already well established) initiated or supported some large-scale infrastructure projects in the region. The Association of Southeast Asia Nations (ASEAN) has put much effort into promoting connectivity concept both within the Association and via the Regional Comprehensive Economic Partnership (RCEP). Korean President Pak officially presented a Eurasian initiative. India started to position itself as a continental power and proposed an idea of a new North–South corridor—a cross-Eurasian trade route. China also put its project ‘One Belt, One Road’ (OBOR) into the centre of its foreign economic policy, cultural diplomacy, military strategy, and internal strategic development. Russia put such initiatives as modernisation and promotion of the northern sea route and renovation of the Trans-Siberian route as important objectives of national development policy. This chapter investigates the role of Russian Siberia and the Far East—33 % of the territory of the Asian continent—in these new strategic plans. Our finding is that a place has already been found for the Russian Far East on a new infrastructure map of Eurasia, but Siberia remains mostly excluded from all the key projects despite its enormous resources and technological and human potential. Analysis of official documents, development strategies, business news, and transport budget allocation all support this proposition. It appears that there is a serious challenge for Russian authorities (both federal and regional), while Siberian development policy needs to be reconsidered and written into cross-border and continental projects—not only in the long-existing transit dream of the Trans-Siberian route.