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A Brave New Post Beps World New Double Tax Treaty Between Germany And Australia Implements Beps Measures
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Book Synopsis A Brave New Post-BEPS World : New Double Tax Treaty Between Germany and Australia Implements BEPS Measures by : L. Maurer
Download or read book A Brave New Post-BEPS World : New Double Tax Treaty Between Germany and Australia Implements BEPS Measures written by L. Maurer and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The article analyses the key features of the new tax treaty between Germany and Australia, which entered into force on 7 December 2016. The treaty was signed on 12 November 2015 and replaces the existing treaty between both countries signed in 1972. The treaty is one of the first double tax treaties to be concluded globally since the finalization of the OECD BEPS Action Plan and thus represents a significant landmark on the global tax landscape that may indicate the trajectory of post-BEPS double tax treaties. The treaty applies from 1 January 2017 in Germany and from 1 January 2017 (withholding tax), 1 April 2017 (fringe benefits tax) and 1 July 2017 (other Australian taxes) respectively in Australia.
Book Synopsis The New Permanent Establishment by : Tiago Gonçalves Marques
Download or read book The New Permanent Establishment written by Tiago Gonçalves Marques and published by Leya. This book was released on 2023-04-21 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
Book Synopsis The 2015 Australia-Germany Tax Treaty, BEPS, and the Multilateral Instrument by : C.J. Taylor
Download or read book The 2015 Australia-Germany Tax Treaty, BEPS, and the Multilateral Instrument written by C.J. Taylor and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the influence of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project, prior Australian tax treaty practice, the OECD Model and German tax treaty practice on the 2015 Australia-Germany Tax Treaty (the 2015 Treaty). Reference is made in this article to the Explanatory Memorandum to International Tax Agreements Amendment Bill 2016 in ascertaining the influence of the BEPS recommendations, German tax treaty practice and prior Australian treaty practice on the treaty. Provisions in the 2015 Treaty were compared with recommendations and discussions in the various reports issued by the OECD as part of the BEPS project to determine the extent to which the treaty provisions reflected the BEPS recommendations. To determine whether particular provisions showed the influence of German tax treaty practice, they were compared with the German Model Tax Treaty as published by the German Ministry of Finance. To determine whether particular provisions were consistent with past idiosyncratic features of Australian tax treaty practice, they were compared with provisions in prior Australian tax treaties, with archival records of Australian tax treaty negotiations and with the results of prior investigations of Australian tax treaty practice. The article argues that in future Australia should make further adjustments to its tax treaty practice in a post-BEPS and Multilateral Instrument environment.
Book Synopsis The Concept of Permanent Establishment in the Insurance Business by : Daniele Frescurato
Download or read book The Concept of Permanent Establishment in the Insurance Business written by Daniele Frescurato and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Book Synopsis Principles of International Taxation by : Lynne Oats
Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 773 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Book Synopsis Permanent Establishment by : Arvid Aage Skaar
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux
Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Book Synopsis Taxation and Democracy by : Sven Steinmo
Download or read book Taxation and Democracy written by Sven Steinmo and published by Yale University Press. This book was released on 1993-01-01 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: Examining the structure, politics and historic development of taxation in several countries, this book compares three quite different political democracies. It provides an account of the ways these democracies have financed their welfare programs despite w
Download or read book Brittle Power written by Amory B. Lovins and published by . This book was released on 1982 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis An Introduction to International Organizations Law by : Jan Klabbers
Download or read book An Introduction to International Organizations Law written by Jan Klabbers and published by Cambridge University Press. This book was released on 2022-03-10 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides a framework for understanding how organizations are set up and the logic behind international organizations law.
Download or read book Productive Equity written by Zia Qureshi and published by Brookings Institution Press. This book was released on 2019-02-26 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: An agenda for economic growth and equity In recent decades global economic productivity has slowed, while income inequality within nations has increased. The global economic pie has been growing more slowly—and more unequally—feeding the social discontent that is so evident in much of the world today. The contributors to this volume argue that the paradox of slowing productivity growth despite booming new technologies is real, not illusory. Most discussions of these trends in productivity growth and income distribution treat them as separate problems, with independent solutions. This book by economic experts with long experience in studying the global economy and development argues that lagging productivity and growing inequality are, in fact, linked by common causes and must have common solutions. Chief among those causes are the nature of today’s technological changes and the failures of markets and policymakers to keep up with those changes. In essence, the potential benefits of technological change, which coincided with the era of accelerated globalization, have not been harnessed to foster more robust, and more inclusive, economic growth. The authors maintain that reviving productivity growth and reducing inequality are not competing objectives for policy. Rather, they propose an integrated agenda emphasizing the synergistic nature of achieving long-term productivity growth and equity. The authors call for an agenda of "productive equity" that highlights the need for innovative policies, at both the national and international levels, that take advantage of the technological changes now reshaping markets and the world of work.
Book Synopsis Better Pensions, Better Jobs by : Mariano Bosch
Download or read book Better Pensions, Better Jobs written by Mariano Bosch and published by Inter-American Development Bank. This book was released on 2013-10-16 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Latin America and Caribbean (LAC) region has reduced its inequality and poverty, and is looking towards the future with greater optimism than in the past. As the region grows, new problems appear that economic policymakers must address. How to provide adequate pensions for the elderly is one such problem. This book offers an analysis of pension systems from the perspective of the functioning of the regions labor markets. It clarifies why, more than half a century after pension systems were created, only a minority of workers in the region save for their pension in the contributory systems through payroll taxes. The study points out that the problem lies not only in the lack of coverage, but also in the low level of benefits, even of contributory pensions. It argues that to design public policies for pensions, it is essential to understand the complex web of interactions between employers and workers that take place in the labor market.
Download or read book Does Atlas Shrug? written by Joel Slemrod and published by Harvard University Press. This book was released on 2000 with total page 540 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the introduction of the income tax in 1913, controversy has raged about how heavily to tax the rich. Opponents of high tax rates claim that heavy assessments have negative incentives on the productivity of some of our most talented citizens; supporters stress the importance of the rich shouldering their "fair share," and decry the loopholes that permit many to escape their obligations. Notably absent from this debate is hard evidence about the actual impact of taxes on the behavior of the affluent. This book presents evidence by leading economists of the effects of taxes on the formation of businesses, the supply of labor, the form of executive compensation, the accumulation of wealth, the allocation of portfolios, and the realization of capital gains. Among its findings are that the labor supply of the rich remained unchanged in the face of large tax cuts in 1986, and that in late 1992 executives exercised billions of dollars' worth of stock options in order to beat the tax increases expected in 1993. The book also presents a history of efforts to tax the rich, a demographic snapshot of the financially affluent, and a road map to widely used tax-avoidance strategies. Does Atlas Shrug? will be of great interest to policymakers and interested citizens who want to know how much tax revenue could really be gained by increasing tax rates on the rich, or whether low capital gains tax rates really spur economic growth.
Download or read book The Joy of Tax written by Richard Murphy and published by Random House. This book was released on 2015-10-01 with total page 314 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'A brief but crucially important book' Marcus Chown In The Joy of Tax, tax campaigner Richard Murphy challenges almost every idea you have about tax. For him, tax is fundamentally about the ideas that shape the sort of society we want to live in, not technicalities. His intention is to demonstrate that there is indeed a joy in tax, and by embracing it we can create a fairer society and change the world for the better. Tax has been a feature of human society for a very long time. Almost no one gives tax a good press even though, as Richard Murphy argues, it has been fundamental to the development of democracy the world over. Whilst we may not like tax very much, in contrast it is clear that we really do like the public services which governments provide. So much so, in fact, that for most of the last 300 years, people have been more than happy for governments to run deficits by spending more than they raise in taxation. 2008 apparently changed all that. The issues of debt, deficits, cuts and austerity have dominated the political agenda ever since. Virtually every aspect of the government's finances and how to rearrange them in the forlorn hope of balancing the books has been discussed in great detail. Despite that, there has been almost no real discussion during this period about what tax is for and how it contributes to the creation of the society we aspire to.
Book Synopsis Harmful Tax Competition An Emerging Global Issue by : OECD
Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Book Synopsis The 2008 Global Financial Crisis in Retrospect by : Robert Z. Aliber
Download or read book The 2008 Global Financial Crisis in Retrospect written by Robert Z. Aliber and published by Springer. This book was released on 2019-06-01 with total page 443 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the causes and consequences of the international financial crisis of 2008. A range of esteemed contributors explore developments in the United States, where the crisis of 2008 originated, as well as the smallest country affected, Iceland, by evaluating developments since 2008. Currently, many countries are facing similar problems as Iceland did in 2008: this book is of interest to economists and policy makers in these countries to study what happened in Iceland, and why the recovery of that economy was strong and swift. The chapters in this book originate from panel discussions and conferences and explore areas including regulation, state projects and inflation.
