RSS 1.0Kwartalnik Prawa Podatkowego 2023, nr 4
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SPIS TREŚCI
1. The 2017 and 2021 UN Model Tax Convention Updates and Their Impact on the Countries’ Treaty PracticeJan J.P. de Goede
2. The Brazil-Poland Double Tax Convention in the Context of the Countries’ Contemporary Tax Treaty Policy and Practice
Ziemowit Kukulski
3. An Analysis of the Principal Purpose Test Rule and the General Anti-Abuse Rules Contained in the Brazil-Poland Double Taxation Convention Signed in September 2022
Marciano Seabra de Godoi, Melody Araújo Pinto Furman
4. Exit Taxation and the DTT Between Poland and Brazil
Aneta Nowak-Piechota
5. The Remuneration of Teachers and Researchers under Art. 21 of the Brazil-Poland Double Taxation Convention of 2022 in the Light of the Polish Treaty Practice
Małgorzata Sęk
6. A Discussion on the International Tax Issues Arising in Chinese Enterprises’ Investments to Brazil
Tan Yusen
7. The Constitutionalisation of the Tax Sovereignty of European Autonomous Territories
Monika Bogucka-Felczak, Patryk Kowalski
8. Polish Concession Fee on Offshore Wind Farms: A Quasi-Tax Hidden in the Energy Law
Adam Kałążny, Wojciech Morawski
9. Reporting Tax Schemes Violates Legal Professional Privilege
Ewa Prejs
10. The Income Tax Designation for the Benefit of PBOs: Correct Financial Support for Public Benefit Activities by Taxpayers Within the Institution of the Income Tax Designation?
Maria Supera-Markowska
11. The VAT Treatment of Cryptocurrencies
Anna Nykiel-Mateo
12. What can I do for Europe?
Włodzimierz Nykiel
Najnowsze pozycje
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The VAT Treatment of Cryptocurrencies
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)Since their creation in 2009, crypto-assets have evolved from niche products into assets held and used much more widely. These assets pose challenges for policymakers and tax administrations, because, as pointed out by the ... -
What can I do for Europe?
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30) -
The Constitutionalisation of the Tax Sovereignty of European Autonomous Territories
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)This article presents the results of a comparative legal research concerning tax sovereignty granted to 13 European autonomous territories by constitutional law. Research material includes the constitutions of the main ... -
Polish Concession Fee on Offshore Wind Farms: A Quasi-Tax Hidden in the Energy Law
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)The production of electricity using offshore wind farms is at a preparatory stage in Poland. However, it has the opportunity to become the most dynamically-developing segment of the power industry, especially considering ... -
Reporting Tax Schemes Violates Legal Professional Privilege
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)In this article, the author discusses the judgment of the CJEU in the case C-694/20 Orde van Vlaamse Balies and Others, which extends the protection of professional secrecy for lawyers. In the context of combating aggressive ... -
The Income Tax Designation for the Benefit of PBOs: Correct Financial Support for Public Benefit Activities by Taxpayers Within the Institution of the Income Tax Designation?
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)Since 1st January, 2004, the institution of a designation of part of the income tax in favour of public benefit organisations has been functioning in the Polish tax system. The right to the allocation may be exercised by ... -
A Discussion on the International Tax Issues Arising in Chinese Enterprises’ Investments to Brazil
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)Brazil is a member state of the Golden BRICS and the biggest economy in South America. China is also a member state of the Golden BRICS and the second biggest economy in the world. To enhance mutual economic cooperation ... -
The Remuneration of Teachers and Researchers under Art. 21 of the Brazil-Poland Double Taxation Convention of 2022 in the Light of the Polish Treaty Practice
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)The aim of this paper is to analyze an exemption addressed to visiting teachers and researchers included in Art. 21 of the Agreement between the Republic of Poland and the Federative Republic of Brazil for the elimination ... -
Exit Taxation and the DTT Between Poland and Brazil
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)The article addresses the issue of double taxation elimination in cases involving the application of an exit tax under the DTT between Poland and Brazil, which was signed in 2022. The author explains the key characteristics ... -
An Analysis of the Principal Purpose Test Rule and the General Anti-Abuse Rules Contained in the Brazil-Poland Double Taxation Convention Signed in September 2022
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)The paper deals with the analysis of the legal aspects of the principal purpose test rule (PPT-Rule) and the general anti-abuse rules contained in the Brazil-Poland Double Tax Convention concluded on 20th September, 2022, ... -
The Brazil-Poland Double Tax Convention in the Context of the Countries’ Contemporary Tax Treaty Policy and Practice
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)This paper deals with the Brazil-Poland double tax convention for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, signed on 20th September, 2022, in the ... -
The 2017 and 2021 UN Model Tax Convention Updates and Their Impact on the Countries’ Treaty Practice
(Wydawnictwo Uniwersytetu Łódzkiego, 2023-12-30)This paper deals with the 2017 and 2021 UN Model updates and their possible impact on countries’ tax treaty policy and practice. The Author provides an overview of the most relevant changes to the text of the UN Models ...