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Romania si dubla impozitare internationala
ROMANIA AND INTERNATIONAL DOUBLE TAXATION

Author(s): Radu Buziernescu, Mihai Antonescu
Subject(s): Economy
Published by: Editura Universitaria Craiova
Keywords: double taxation; tax evasion; lending method; progressive exemption method, treaty shopping

Summary/Abstract: The phenomenon of double taxation arises not due to the different structures of tax systems, but due to the different conceptions (criteria) which underlie the taxation. Two conceptions apply in the tax practice: territorial conception, which underlies the source criteria (origin) of revenues or the place where the property is located; and the global and world conception, which underlies the residence criteria (of tax residence) or the nationality of the taxpayer, natural person, respectively of the registered office of the taxpayer, legal person. With the purpose of avoiding the double taxation, our country uses both unilateral legislative measures and the negotiation and conclusion of bilateral or multilateral conventions with the partner states, the two measures of tax harmonization being used simultaneously. Our legislation applies the criteria of territoriality and citizenship regarding the settlement of tax rates, taxes, contributions and other public revenues by means of which the double taxation tries to be avoided.

  • Issue Year: XXXVI/2008
  • Issue No: 6
  • Page Count: 10
  • Language: English