This article analyzes the interaction between domestic tax legislation applied to avoid or combat a brain drain and the OECD and the UN model tax conventions, the two main models used by states in tax treaty negotiations. After it is demonstrated that brain drain taxes are incompatible with the current tax treaty network, the author presents alternatives that could be included in the model tax conventions, and consequently in tax treaties, to establish the compatibility of the measures, as well as a justification for the adoption of these alternatives in tax treaties involving developing countries.
Ključne reči:
Taxation of emigrants / Tax treaties / Tax benefits / Right to development / Brain drain
Izvor:
Anali Pravnog fakulteta u Beogradu, 2019, 67, 4, 249-282
TY - JOUR
AU - Souza, de Man Fernando
PY - 2019
UR - https://ralf.ius.bg.ac.rs/handle/123456789/1763
AB - This article analyzes the interaction between domestic tax legislation applied to avoid or combat a brain drain and the OECD and the UN model tax conventions, the two main models used by states in tax treaty negotiations. After it is demonstrated that brain drain taxes are incompatible with the current tax treaty network, the author presents alternatives that could be included in the model tax conventions, and consequently in tax treaties, to establish the compatibility of the measures, as well as a justification for the adoption of these alternatives in tax treaties involving developing countries.
T2 - Anali Pravnog fakulteta u Beogradu
T1 - Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward
EP - 282
IS - 4
SP - 249
VL - 67
DO - 10.5937/AnaliPFB1904249S
UR - conv_3267
ER -
@article{
author = "Souza, de Man Fernando",
year = "2019",
abstract = "This article analyzes the interaction between domestic tax legislation applied to avoid or combat a brain drain and the OECD and the UN model tax conventions, the two main models used by states in tax treaty negotiations. After it is demonstrated that brain drain taxes are incompatible with the current tax treaty network, the author presents alternatives that could be included in the model tax conventions, and consequently in tax treaties, to establish the compatibility of the measures, as well as a justification for the adoption of these alternatives in tax treaties involving developing countries.",
journal = "Anali Pravnog fakulteta u Beogradu",
title = "Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward",
pages = "282-249",
number = "4",
volume = "67",
doi = "10.5937/AnaliPFB1904249S",
url = "conv_3267"
}
Souza, d. M. F.. (2019). Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward. in Anali Pravnog fakulteta u Beogradu, 67(4), 249-282.
https://doi.org/10.5937/AnaliPFB1904249S
conv_3267
Souza DMF. Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward. in Anali Pravnog fakulteta u Beogradu. 2019;67(4):249-282.
doi:10.5937/AnaliPFB1904249S
conv_3267 .
Souza, de Man Fernando, "Tax measures to combat brain drain: (In) compatibility issues with double tax conventions and a potential way forward" in Anali Pravnog fakulteta u Beogradu, 67, no. 4 (2019):249-282,
https://doi.org/10.5937/AnaliPFB1904249S .,
conv_3267 .
