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Particularities of resolution of problems of the economic entities by application of conventions on avoidance of double taxation (the case of Republic of Moldova)

Author: Criclivaia Diana
Degree:doctor of economics
Speciality: 08.00.10 - Finance; Monetary Economics; Credit
Scientific adviser: Rodica Hîncu
doctor habilitat, professor, Academy of Economic Studies of Moldova
Scientific council:


The thesis was presented on the 15 December, 2007
Approved by NCAA on the 24 January, 2008


Adobe PDF document0.81 Mb / in romanian


CZU 658.1:336.225.676(478)(043)

Adobe PDF document 3.25 Mb / in romanian
166 pages


Double taxation, double - taxation evasion, international fiscal planning, fiscal evasion, transfer price, tax heaven, resident, non - resident, representative, permanent representative, fiscal status, convention model, transnational company, assimetric solution, fiscal rebate, fiscal damage, tax optimization, structuring tax liabilities, fiscal sovereignty


Double taxation is an everlasting international problem that causes fiscal pressure growth and occurrence of tax evasion, slows down economic activities, reduces investment attractiveness and as a result reduces to minimum budgetary financial resources drawn from economic entities.

The doctorate paper covers a research on aspects related to improvement in international taxation of income and capital, identification of a mechanism for effective application of taxation principles at the international level, for purpose of settlement of fiscal problems of economic entities.

An important role in this doctorate paper belongs to: research of causes of occurrence of double taxation in the international taxation practice; analysis of methods to eliminate it, as well as examination of implementation possibilities in the national practice, by using advanced international practices, and the method of entering upon the cost account of the tax paid abroad as an efficient method for avoidance of double taxation for economic entities in the Republic of Moldova; research on methods of tax planning, most frequently used in foreign economic activities, for purpose of identification of advantages and solution of tax problems of economic entities; determination of the taxation status of non-residents operating in the Republic of Moldova for purpose of elaboration of practical recommendations on efficient investments from the taxation perspective.

From practical perspective, by using internationally proven methods, this paper provides recommendations on: improvement of the taxation system in the Republic of Moldova by optimization of taxation of non-residents operating in the Republic of Moldova and domestic companies operating abroad; how to increase efficiency of tax planning; identification of conditions required for efficient investments, from the taxation perspective.

Conclusions and recommendation developed in this paper show some possibilities in solution of problems of economic entities (the case of Republic of Moldova) by application of conventions on avoidance of double taxation.

The completed research can be used by: taxation and regulatory authorities for elaboration of new legislation and improvement of the existing legislation with regard to activity of domestic companies abroad and non-residents in the Republic of Moldova; taxpayers – domestic economic entities and foreign investors, for purpose of adequate tax structuring of total tax obligations, taking into consideration the Moldovan and international tax legislation; foreign companies for evaluation of taxation efficiency in investment projects; didactic personnel in teaching specialty disciplines at economy universities.