Prevention Of Double Taxation
Double taxation has harmful effects on international trade and capital flows so that states conclude bilateral tax treaties superior to national tax rules for the avoidance and prevention double taxation in respect of the most relevant income taxes. The link between the national transfer pricing rules and bilateral tax treaties as well as customs valuation rules must be considered. GRANIT pays specific attention to the effects of bilateral tax treaties on the Turkish transfer pricing regulations.
In addition to this, in July 2013, the OECD published its “Action Plan on Base Erosion and Profit Shifting” (BEPS).The BEPS Action Plan identifies 15 specific actions to address gaps and mismatches in the existing international tax standards, including measures to prevent abuse of tax treaties. For example, BEPS Action 6: Prevent treaty abuse, where BEPS Action 7: Prevent artificial avoidance of permanent establishment status.
Moreover, the spread of the digital economy poses challenges for international taxation. Tax challenges arising from digitalisation, and impact of digitalisation on nexus and profit determination and allocation rules such as user participation, marketing intangibles and significant economic presence.
GRANIT offers minimising fiscal/financial risks arisen from international taxation, double taxation and transfer pricing.
More information please contact with one of our partners.