An International Perspective : Examining how Other Countries Approach Business Taxation

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Publisher :
ISBN 13 :
Total Pages : 184 pages
Book Rating : 4.:/5 (95 download)

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Book Synopsis An International Perspective : Examining how Other Countries Approach Business Taxation by :

Download or read book An International Perspective : Examining how Other Countries Approach Business Taxation written by and published by . This book was released on 1998 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt: This "International Perspective" information paper provides a comparison of Australia's business tax system with those of 26 other countries. Its purpose is to provide information on the way in which other countries approach the taxation of business income and to gain possible insights into the design of taxation policy and legislative processes in other countries.

An International Perspective

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Publisher :
ISBN 13 : 9780642261779
Total Pages : 183 pages
Book Rating : 4.2/5 (617 download)

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Book Synopsis An International Perspective by :

Download or read book An International Perspective written by and published by . This book was released on 1998 with total page 183 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Proper Tax Base

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041141987
Total Pages : 355 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The Proper Tax Base by : Yariv Brauner

Download or read book The Proper Tax Base written by Yariv Brauner and published by Kluwer Law International B.V.. This book was released on 2012-03-01 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world’s most respected international tax experts—including the late Paul McDaniel, in whose honor these essays were assembled—this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of “horizontal equity”; the international tax norm of “income source”; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.

Global Perspectives on Income Taxation Law

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Publisher : Oxford University Press
ISBN 13 : 0199717451
Total Pages : 202 pages
Book Rating : 4.1/5 (997 download)

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Book Synopsis Global Perspectives on Income Taxation Law by : Reuven Avi-Yonah

Download or read book Global Perspectives on Income Taxation Law written by Reuven Avi-Yonah and published by Oxford University Press. This book was released on 2010-12-01 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Global Perspectives on Income Taxation Law, Reuven Avi-Yonah, Nicola Sartori, and Omri Marian cover basic, corporate and international tax law from a comparative perspective. The book both supplements readings in US tax law courses and serves as a textbook for a comparative tax law class. The book starts with a theoretical analysis of the field of comparative tax law. It then follows the usual order of topics covered in a basic tax course as taught in most U.S. law schools, and for each topic, the authors highlight possible alternatives or policy choices. The authors frequently consider the U.S. approach as a benchmark, comparing it with approaches used in other countries which form an interesting contrast, or a telling similarity. They consider the multiple purposes of studying comparative tax law: helping to advance successful tax reforms, cultural understanding, political values, legal harmonization, and a better understanding of domestic tax laws.

Basic International Taxation

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Publisher : Springer
ISBN 13 : 9789041198525
Total Pages : 0 pages
Book Rating : 4.1/5 (985 download)

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Book Synopsis Basic International Taxation by : Roy Rohatgi

Download or read book Basic International Taxation written by Roy Rohatgi and published by Springer. This book was released on 2001-12-21 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of international economic activities presents two essential considerations: revenues must be shared equitably by the nations involved, and those nations must be able to enforce their domestic tax laws. Starting from these requirements of reciprocity and enforcement, the author explains in this book the practical issues affecting international taxation of business income and capital gains. Unlike many books on this complex subject, his approach does not examine the tax perspective of any one country, but proceeds from an identification and analysis of the basic principles of the subject. This entails an understanding of factors, such as: domestic tax laws, rules and practices and how they conflict on cross-border transactions; bilateral tax treaties and their role in resolving international tax conflicts; the use of offshore financial centres in international tax structures and how to choose them; anti-avoidance measures imposed by national taxation authorities; and international tax guidelines and interpretations of bodies such as the Organisation for Economic Cooperation and Development (OECD) and the International Fiscal Association (IFA). Basic International Taxation describes each and all of these elements, weaving them into practical planning guidance providing a fundamental understanding of this subject in a single, easy-to-follow book. It explains those principles of international tax planning that take the costs and risks of international taxation fully into account and thereby optimize the after-tax returns on cross-border transactions. Several important current issues, including the taxation of electronic commerce, are also addressed.

Comparative Income Taxation

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Publisher : Kluwer Law International B.V.
ISBN 13 : 904113204X
Total Pages : 594 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Comparative Income Taxation by : Hugh J. Ault

Download or read book Comparative Income Taxation written by Hugh J. Ault and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 594 pages. Available in PDF, EPUB and Kindle. Book excerpt: The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.

Cross-Border Taxation of Permanent Establishments

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041168389
Total Pages : 362 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Cross-Border Taxation of Permanent Establishments by : Andreas Waltrich

Download or read book Cross-Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.

An Examination of U.S. Tax Policy and Its Effects on the International Competitiveness of U.S.-owned Foreign Operations

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Publisher :
ISBN 13 :
Total Pages : 292 pages
Book Rating : 4.:/5 (327 download)

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Book Synopsis An Examination of U.S. Tax Policy and Its Effects on the International Competitiveness of U.S.-owned Foreign Operations by : United States. Congress. Senate. Committee on Finance

Download or read book An Examination of U.S. Tax Policy and Its Effects on the International Competitiveness of U.S.-owned Foreign Operations written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2004 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Taxation of Cross-border Partnerships

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Publisher : IBFD
ISBN 13 : 9076078858
Total Pages : 431 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis Taxation of Cross-border Partnerships by : Jesper Barenfeld

Download or read book Taxation of Cross-border Partnerships written by Jesper Barenfeld and published by IBFD. This book was released on 2005 with total page 431 pages. Available in PDF, EPUB and Kindle. Book excerpt: Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."

OECD Economic Surveys: New Zealand 2000

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Publisher : OECD Publishing
ISBN 13 : 9264175865
Total Pages : 217 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis OECD Economic Surveys: New Zealand 2000 by : OECD

Download or read book OECD Economic Surveys: New Zealand 2000 written by OECD and published by OECD Publishing. This book was released on 2000-11-29 with total page 217 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2000 edition of OECD's periodic economic reviews of New Zealand exaines recent economic developments, policies and prospects and includes special features on structural reform and improving the tax system.

Studies in International Taxation

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Publisher : University of Chicago Press
ISBN 13 : 9780226297019
Total Pages : 322 pages
Book Rating : 4.2/5 (97 download)

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Book Synopsis Studies in International Taxation by : Alberto Giovannini

Download or read book Studies in International Taxation written by Alberto Giovannini and published by University of Chicago Press. This book was released on 1993-09-15 with total page 322 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents research on how taxes affect the investment and financing decisions of multinationals. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies.

Tax Notes International

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Publisher :
ISBN 13 :
Total Pages : 1264 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Tax Notes International by :

Download or read book Tax Notes International written by and published by . This book was released on 2004 with total page 1264 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Why Corporate Taxation Should Mean Source Taxation : a Response to the OECD's Actions Against Base Erosion and Profit Shifting

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Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (126 download)

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Book Synopsis Why Corporate Taxation Should Mean Source Taxation : a Response to the OECD's Actions Against Base Erosion and Profit Shifting by : L.U. Cavelti

Download or read book Why Corporate Taxation Should Mean Source Taxation : a Response to the OECD's Actions Against Base Erosion and Profit Shifting written by L.U. Cavelti and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the "country of source". This article questions separate taxation based on this distinction between the country of residence and the country of source. It argues for a departure from the traditional international allocation of the right to tax corporate income and suggests that a corporate entity should instead pay income tax exclusively to the countries in which it has relevant business activities. In other words, this article advocates a "source-based corporate income tax", meaning the global allocation of corporate income based on the source of income. Moreover, in examining the question of where business activities of multinational corporations effectively take place, this article describes criteria for determining source countries. Furthermore, it offers a method for formulary apportionment of corporate income between those countries in which a given multinational corporation generates income. The article argues that source taxation of corporate income would be coherent with the economic nature of corporate income taxation. Source taxation of corporate income would also make the arbitrary concept of corporate residence irrelevant, and it would allow the outdated legal concept of permanent establishment to be abolished. This article takes an interdisciplinary approach to argue from both legal and economic perspectives. It adds to the body of literature that discusses how countries should tax corporate entities doing business across national borders. It also contributes to the ongoing debate about the OECD's recent controversial efforts to prevent corporations shifting profits between countries to minimize their exposure to national tax systems (base erosion and profit sharing, or BEPS).

OECD Papers

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Publisher :
ISBN 13 :
Total Pages : 624 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis OECD Papers by :

Download or read book OECD Papers written by and published by . This book was released on 2000 with total page 624 pages. Available in PDF, EPUB and Kindle. Book excerpt: A compilation of reports previously issued by the OECD.

Why Corporate Taxation Should Mean Source Taxation

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Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (137 download)

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Book Synopsis Why Corporate Taxation Should Mean Source Taxation by : Luzius U. Cavelti

Download or read book Why Corporate Taxation Should Mean Source Taxation written by Luzius U. Cavelti and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the "country of source". This article questions separate taxation based on this distinction between the country of residence and the country of source. It argues for a departure from the traditional international allocation of the right to tax corporate income and suggests that a corporate entity should instead pay income tax exclusively to the countries in which it has relevant business activities. In other words, this article advocates a "source-based corporate income tax", meaning the global allocation of corporate income based on the source of income. Moreover, in examining the question of where business activities of multinational corporations effectively take place, this article describes criteria for determining source countries. Furthermore, it offers a method for formulary apportionment of corporate income between those countries in which a given multinational corporation generates income. The article argues that source taxation of corporate income would be coherent with the economic nature of corporate income taxation. Source taxation of corporate income would also make the arbitrary concept of corporate residence irrelevant, and it would allow the outdated legal concept of permanent establishment to be abolished. This article takes an interdisciplinary approach to argue from both legal and economic perspectives. It adds to the body of literature that discusses how countries should tax corporate entities doing business across national borders. It also contributes to the ongoing debate about the OECD's recent controversial efforts to prevent corporations shifting profits between countries to minimize their exposure to national tax systems (base erosion and profit sharing, or BEPS).Full-text Paper.

Policies to Boost Australian Saving

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Publisher : Wakefield Press
ISBN 13 : 9780958639521
Total Pages : 192 pages
Book Rating : 4.6/5 (395 download)

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Book Synopsis Policies to Boost Australian Saving by : Owen Covick

Download or read book Policies to Boost Australian Saving written by Owen Covick and published by Wakefield Press. This book was released on 2002 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: Most Australian wage and salary earners are now required by the Commonwealth government to save nine per cent of their earnings and to have that money 'locked-away' until they reach a prescribed age. Why is that?

Exploring the Nexus Doctrine In International Tax Law

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403533641
Total Pages : 234 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh

Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.