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Tax Treaty Between
Albania
and
Italy
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Download:
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Not Available
(opens in new window) |
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File Type:
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Status:
In Force
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Number of
Albania
Treaties:
23
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See All
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Number of
Italy
Treaties:
34
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See All
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Introductory note on Tax Treaty Planning
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Tax Treaties (double taxation agreements or DTAs) are international agreements or
conventions concluded with the object of eliminating double taxation by the contracting
states. To succeed in international tax planning, it is essential to engage in deep
and far-reaching calculations. Tax treaties themselves and the OECD Commentary on
the Model Convention give you practical hands-on guidance on international tax planning
issues.
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Treaty Shopping under the
Albania
–
Italy
Tax Treaty
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Treaty shopping is the use of a tax treaty by a person resident in a country that
is not a party to the treaty, i.e. in the present instance by someone who is a resident
of neither
Albania
nor
Italy. However, it is becoming
more and more difficult to use provisions, which were intended to prevent double
taxation, in such a way that they result, for the purposes of an international tax
plan.
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Tax Treaty news from the OECD
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The OECD has released two reports submitted to its Committee on Fiscal Affairs by
an Informal Consultative Group of business and government representatives. The Reports
address, respectively:
(a) Technical issues relating to granting treaty benefits with respect to income
of collective investment vehicles; and
(b) Procedural barriers to claims for treaty benefits that affect portfolio investors
more generally.
These are issues which may impact on international tax planning transactions.
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Know your Offshore Terms:
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| | It is both lawful and sensible to arrange business and personal affairs in such a way as to attract the lowest possible incidence of tax. The widening scope of tax laws, the complexity of their provisions, and high tax rates make it more necessary than ever for business enterprises and individuals alike to plan their taxable events with considerable care. | | | | | Cross-border initial public offerings (“IPOs” or listings) on offshore and foreign exchanges create the opportunity to access hitherto untapped financial markets. As a general rule, open-ended funds tend to list on offshore exchanges where the IPO requirements are less onerous than on the major exchanges. The Dublin stock exchange has gone out of its way to attract funds, as have exchanges in a number of tax havens or international offshore financial centers (IOFCs), such as Bermuda, the Cayman Islands, the Channel Islands and Luxembourg. | | | | | Article 4.1 of the OECD Model Convention deals with the question of corporate residence by reference to “the place of management or any other criterion of a similar nature”. Note, however, that the definition of a resident of a Contracting State in specific treaties may exclude foreign held companies which are exempt from tax on their foreign income. This point should be watched in developing a corporate international tax plan. | | | | | Where opportunities arise to purchase a single item for resale at a substantial profit, a company in a tax haven or international offshore financial center (IOFC) could be used to take the profit (e.g. purchase of liquidation goods, etc.). A similar structure could be used for a bulk purchase of goods for subsequent on¬-sale in smaller lots. Substantial discounts may be obtained by purchasing in bulk from third parties for onward sale to group companies or third parties. An offshore purchase and sales company may, for these reasons, be included in an international tax plan. | | |
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