Problematyka umów zapobiegających podwójnemu opodatkowaniu
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Date
1989
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Wydział Prawa i Administracji UAM
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The problems of agreements to prevent double taxation
Abstract
Undertaking economic activity by natural and legal persons on territories of
foreign countries brings about many legal and organizational problems, connected
mostly with double taxation.
Double taxation may appear in internal and international relations. It may
be of economic or legal character.
Preventing double taxation may consist in unilateral, partial or full, renouncement
by the State of the rights to collect taxes, in concluding bilateral agreements
with respect to double taxation, the agreements which to a considerable
extent eliminate double taxation of economic and legal character, and in concluding
multilateral agreements which have to take into account complicated diversification
of tax systems of various countries.
The first agreements to prevent double taxation were concluded in the 1920s
and 1930 s. However, the majority of such agreements were concluded in the 1970s,
on the basis of a model form of agreement to prevent double taxation worked
out by the OECD. The agreements based on the above model are adequately
modified according to the arrangement of mutual economic relations and the specificity
of tax systems of respective countries.
Nowadays the process of tax unification within regional economic systems
may be observed. In particular, in the EEC countries the said process is known
under the name of „tax harmonization".
In the CMEA countries, a great diversity of tax constructions may be observed,
despite similarities in socio-economic systems of those countries. It seems
that the above diversity has been caused by the adoption of different formuli of
managing the national economy in various countries. However, it may be supposed
that irrespective of those formuli, an attempt to harmonize tax burdens between
the CMEA countries will be undertaken in the future. The most efficient tool to
meet the above aim seems to be international tax agreements through which the
co-ordination harmonization or unification of tax systems of various countries
might best be achieved.
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Digitalizacja i deponowanie archiwalnych zeszytów RPEiS sfinansowane przez MNiSW w ramach realizacji umowy nr 541/P-DUN/2016
Keywords
Citation
Ruch Prawniczy, Ekonomiczny i Socjologiczny 51, 1989, z. 2, s. 119-128.
Seria
ISBN
ISSN
0035-9629