Posts published in “South America”

International Taxation of E-commerce Business Income

By Editor on December 6, 2019

Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international tax principles that are structured…

Double Tax Treaties: An Introduction

By Editor on December 3, 2019

Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current…

ANTI-AVOIDANCE MEASURES OF GENERAL NATURE AND SCOPE-GAAR AND OTHER RULES

By Editor on December 2, 2019

Paper by: Guillermo O. Teijeiro Most countries have either judicial or statutory general anti-avoidance rules (GAAR); Argentina enrols in the second group as GAAR are…

PARAGUAY – “Tax treaty overrides: tension between Paraguayan Constitutional Law and the Vienna Convention on the Law of Treaties. An economic and legal analysis of the feasibility of implementing Double Taxation Treaties with uncertain reciprocity” – Lui Carísimo

By Editor on November 26, 2019

DTC are binding agreements between usually two States and thus are governed by Public International Law. In the majority of jurisdictions, the introduction of DTC…