INCOME TAX TREATIES, WITH PARTICULAR REGARD FOR THE CONVENTION BETWEEN U.S. AND ITALY
De Girolamo, Giuseppe (2011) INCOME TAX TREATIES, WITH PARTICULAR REGARD FOR THE CONVENTION BETWEEN U.S. AND ITALY. [Tesi di dottorato] (Inedito)
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Double taxation has a detrimental effect on the movement of capital, technology and persons and on the exchange of goods and services. Tax conventions, when properly applied, remove the obstacles of double taxation, thereby promoting the development and flow of international trade and investment. Hence, one of the most important roles of double income treaties is to remove the double taxation and to beat these obstacles for cross-border economic transactions. The globalization of financial markets and the backdrop of the financial crisis have caused international cooperation in tax matters to increase in importance. Treaties try to remove double taxation in two ways. First of all, tax agreements delineate specific types of income (e.g., dividends and interest) and provide special rules to tax these items. It can be said that in a tax treaty the source country generally gives way to the recipient’s country of domicile. Tax agreements usually provide that under certain conditions the recipient of a particular item of income is taxed at a lower tax rate or is exempted from taxation in the source country. The second way to remove double imposition goes through the establishment of “competent authority” procedures, that provide to taxpayers the chance to present disputes about treaty dispositions to the officials of their home countries for resolution.
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