This article outlines the significance of the digital economy,highlighting the challenges to taxation,and introducing the focus of the article on Azerbaijan's perspective.In recent decades,the digital revolution h...This article outlines the significance of the digital economy,highlighting the challenges to taxation,and introducing the focus of the article on Azerbaijan's perspective.In recent decades,the digital revolution has transformed the global economy,reshaping industries,business models,and consumer behavior at an unprecedented pace.This transformation,commonly referred to as the digital economy,encompasses a broad spectrum of activities ranging from e-commerce and digital services to data analytics and cloud computing.As the digital economy continues to expand its influence,traditional tax systems face significant challenges in adapting to this new reality.This has ignited discussions worldwide across various legal and regulatory domains,and international taxation is no exception.The tax consequences are extensive,impacting both direct and indirect taxation,broader tax policy matters,and tax administration.展开更多
The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant ref...The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.展开更多
The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of ...The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.展开更多
The confluence of several factors including government fiscal pressures and growing opportunities for tax minimization in a digital economy prompted the OECD to embark on a program to reduce base erosion and profit sh...The confluence of several factors including government fiscal pressures and growing opportunities for tax minimization in a digital economy prompted the OECD to embark on a program to reduce base erosion and profit shifting(BEPS).At the same time,countries became increasingly unhappy about international tax rules that left them unable to impose income taxes on companies earning profits by selling to customers inside their country without establishing a taxable presence there.The frustration led to unilateral responses that prompted the OECD to develop proposals to address this problem as well.The OECD’s proposals to reduce profit shifting and enhance taxing rights of sales destination countries evolved into what are now known as Pillar One and Pillar Two international tax reforms.This paper provides an overview of the operation of each of the Pillars and notes the limitations that prevent them from addressing the underlying causes of profit shifting and providing full taxing rights to sales destination jurisdictions.展开更多
This article aims to assess the significance of electronic commerce(e-commerce)and digitalization,and examine the existing taxation practices both globally and in the Republic of Azerbaijan.In contrast to traditional ...This article aims to assess the significance of electronic commerce(e-commerce)and digitalization,and examine the existing taxation practices both globally and in the Republic of Azerbaijan.In contrast to traditional trade,e-commerce relies on modern digital solutions for conducting business operations.When we examine the statistics of e-commerce turnover,it becomes evident that both globally and within the Republic of Azerbaijan,there has been a consistent upward trajectory in turnover over the years.Consequently,it is imperative to emphasize the significance of regulating activities stemming from various emerging trends in e-commerce and adopting a more intricate approach to electronic tax accounting for non-resident entities engaged in e-commerce.展开更多
Propellants containing micro-aluminium particles have been shown to produce faster burn rates than conventional gun propellants.However,they are also more abrasive than conventional propellants.Nano-material propellan...Propellants containing micro-aluminium particles have been shown to produce faster burn rates than conventional gun propellants.However,they are also more abrasive than conventional propellants.Nano-material propellants have been reported to give similar benefits to micron-material propellants but without the disadvantage of increased abrasion.Tests were conducted to compare the burn rates,ignitability and wear rates of a propellant loaded with 0% aluminium,15% micro-aluminium and 15%nano-aluminium.Closed vessel tests showed a burn rate increase of 39% in the range 30-250 MPa,and 70% at low pressure(50-100MPa)for the nano-aluminium propellant compared with the baseline propellant.The micro-aluminium propellant showed only a 10%increase in the burn rate compared with the standard propellant.The ignition delay for the nano-aluminium propellant was slightly shorter than that of the baseline propellant.Substantially increased wear rates were measured for the micro-aluminium propellant.The nano-aluminium propellant showed reduced wear rates compared with the micro-aluminium propellant but these were still substantially greater than those for the baseline propellant.展开更多
文摘This article outlines the significance of the digital economy,highlighting the challenges to taxation,and introducing the focus of the article on Azerbaijan's perspective.In recent decades,the digital revolution has transformed the global economy,reshaping industries,business models,and consumer behavior at an unprecedented pace.This transformation,commonly referred to as the digital economy,encompasses a broad spectrum of activities ranging from e-commerce and digital services to data analytics and cloud computing.As the digital economy continues to expand its influence,traditional tax systems face significant challenges in adapting to this new reality.This has ignited discussions worldwide across various legal and regulatory domains,and international taxation is no exception.The tax consequences are extensive,impacting both direct and indirect taxation,broader tax policy matters,and tax administration.
文摘The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.
文摘The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.
文摘The confluence of several factors including government fiscal pressures and growing opportunities for tax minimization in a digital economy prompted the OECD to embark on a program to reduce base erosion and profit shifting(BEPS).At the same time,countries became increasingly unhappy about international tax rules that left them unable to impose income taxes on companies earning profits by selling to customers inside their country without establishing a taxable presence there.The frustration led to unilateral responses that prompted the OECD to develop proposals to address this problem as well.The OECD’s proposals to reduce profit shifting and enhance taxing rights of sales destination countries evolved into what are now known as Pillar One and Pillar Two international tax reforms.This paper provides an overview of the operation of each of the Pillars and notes the limitations that prevent them from addressing the underlying causes of profit shifting and providing full taxing rights to sales destination jurisdictions.
文摘This article aims to assess the significance of electronic commerce(e-commerce)and digitalization,and examine the existing taxation practices both globally and in the Republic of Azerbaijan.In contrast to traditional trade,e-commerce relies on modern digital solutions for conducting business operations.When we examine the statistics of e-commerce turnover,it becomes evident that both globally and within the Republic of Azerbaijan,there has been a consistent upward trajectory in turnover over the years.Consequently,it is imperative to emphasize the significance of regulating activities stemming from various emerging trends in e-commerce and adopting a more intricate approach to electronic tax accounting for non-resident entities engaged in e-commerce.
基金funded by the Defence Science and Technology Laboratory(Dstl)part of the UK MoD,under the Hazard Modelling and Simulation task of the UK Energetics(UK-E)programme now consumed by the Weapons Science and Technology Centre(WSTC)
文摘Propellants containing micro-aluminium particles have been shown to produce faster burn rates than conventional gun propellants.However,they are also more abrasive than conventional propellants.Nano-material propellants have been reported to give similar benefits to micron-material propellants but without the disadvantage of increased abrasion.Tests were conducted to compare the burn rates,ignitability and wear rates of a propellant loaded with 0% aluminium,15% micro-aluminium and 15%nano-aluminium.Closed vessel tests showed a burn rate increase of 39% in the range 30-250 MPa,and 70% at low pressure(50-100MPa)for the nano-aluminium propellant compared with the baseline propellant.The micro-aluminium propellant showed only a 10%increase in the burn rate compared with the standard propellant.The ignition delay for the nano-aluminium propellant was slightly shorter than that of the baseline propellant.Substantially increased wear rates were measured for the micro-aluminium propellant.The nano-aluminium propellant showed reduced wear rates compared with the micro-aluminium propellant but these were still substantially greater than those for the baseline propellant.
