Ahmed, Muhammad Ashfaq
UN MTC Article 8 was the source rule surrender on Article 8 a blunder? The case study of Pakistan / Muhammad Ashfaq Ahmed .-- , 2020
Resumen.
The United Nations Model Tax Convention (UN MTC) Article 8 allocates taxing rights on international traffic to the state of effective management. Article 8 (Alternative B), however, to the extent of shipping, conditionally allows some taxing rights to source state, too. The study posits that by surrendering source rule on Article 8, UN MTC ditched developing countries. This allowed airlines and shiplines stationed in developed countries not only generate large sums of revenues by hitting developing countries' ports but also repatriate them tax free to a sustained disadvantage to the developing countries.
TRANSPORTES MARITIMOS
TRAFICO MARITIMO
COMERCIO INTERNACIONAL
IMPUESTOS
DOBLE IMPOSICION
PAISES EN DESARROLLO
CONVENIOS
NACIONES UNIDAS
Intertax 0165-2826 v. 48, Issue 1, January 2020, p. 103-118
UN MTC Article 8 was the source rule surrender on Article 8 a blunder? The case study of Pakistan / Muhammad Ashfaq Ahmed .-- , 2020
Resumen.
The United Nations Model Tax Convention (UN MTC) Article 8 allocates taxing rights on international traffic to the state of effective management. Article 8 (Alternative B), however, to the extent of shipping, conditionally allows some taxing rights to source state, too. The study posits that by surrendering source rule on Article 8, UN MTC ditched developing countries. This allowed airlines and shiplines stationed in developed countries not only generate large sums of revenues by hitting developing countries' ports but also repatriate them tax free to a sustained disadvantage to the developing countries.
TRANSPORTES MARITIMOS
TRAFICO MARITIMO
COMERCIO INTERNACIONAL
IMPUESTOS
DOBLE IMPOSICION
PAISES EN DESARROLLO
CONVENIOS
NACIONES UNIDAS
Intertax 0165-2826 v. 48, Issue 1, January 2020, p. 103-118