| Abstract [eng] |
This Master's thesis has consistently analysed the evolution of international taxation and its dualistic concept, which reflects the dual nature of the phenomenon, both in its legal and economic aspects. This thesis identifies the main principles of international taxation, which, in the author's opinion, are the most important in order to ensure a fair and equitable taxation of taxpayers. The analysis of these principles has not only sought to define them, but also to show the relevance and application of the principles of international taxation in a globalised world. The work also examines the problems of international taxation principles, particularly the conflict of principles that arise when countries with different tax treatment claim to tax the same income. This problem is addressed through an analysis of international and national regulations as well as academic works. Furthermore, international taxation and the distribution of taxing rights raise questions about the limitation of state sovereignty, as international taxation regulations may limit the rights of states to tax certain income, depending on its origin and the double taxation treaties concluded. In the course of the analysis of the conflict and the ways of resolving them, the main conflict resolution mechanisms, such as the mutual agreement procedure and arbitration, have been identified and analysed. Finally, the author illustrated, through concrete examples and cases, the main issues of the application of the principles of international taxation and the ways in which they can be reconciled in order to ensure the fair and efficient functioning of international systems and principles. |
