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Apa Programme Introduced In Ireland
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Book Synopsis APA Programme Introduced in Ireland by : D. McSwiney
Download or read book APA Programme Introduced in Ireland written by D. McSwiney and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article provides an overview of Revenue's guidelines on the operation of a new formalised advance pricing agreement (APA) programme, which is effective from 1 July 2016. APAs are intended to minimise the likelihood of double taxation and prevent international tax disputes to complex intercompany transactions.
Book Synopsis Evolution of APA Regime by : Kuldeep Sharma
Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Book Synopsis New Formal APA Programme by : J. Duffy
Download or read book New Formal APA Programme written by J. Duffy and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Ireland has introduced a formal APA programme effective from 1 July 2016 which facilitates the initiation of bilateral APAs in accordance with BEPS best practice. Information on concluded APAs may be exchanged with other jurisdictions under either the OECD spontaneous exchange of information regime or the EU Directive on exchange of information.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14 written by OECD and published by OECD Publishing. This book was released on 2018-08-30 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to ...
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-04-15 with total page 95 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Ireland.
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Book Synopsis The MAP and APA Processes in Ireland by : M. Phelan
Download or read book The MAP and APA Processes in Ireland written by M. Phelan and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This study analyses the mutual agreement procedure (MAP) provided for in art. 25 of the OECD Model Convention. In the first part the authors describe the characteristics of the most common taxpayer cases covered by art. 25(1): transfer pricing cases, permanent establishment cases, dual residence cases and withholding tax cases. The second part of the study provides a detailed examination of all elements of the MAP article in Ireland's income tax treaties and art. 26 in the U.S.-Ireland treaty in particular. In addition, this study deals with advanced pricing agreements (APAs). Ireland's APA program is conducted under the MAP article of the relevant treaty, thus art. 26(3) of the U.S.-Ireland Treaty includes APAs under the MAP article (26). Finally, this study explains purpose and processes in Irelands APA program.
Book Synopsis Program Evaluation Theory and Practice, First Edition by : Donna M. Mertens
Download or read book Program Evaluation Theory and Practice, First Edition written by Donna M. Mertens and published by Guilford Press. This book was released on 2012-03-01 with total page 641 pages. Available in PDF, EPUB and Kindle. Book excerpt: This engaging text takes an evenhanded approach to major theoretical paradigms in evaluation and builds a bridge from them to evaluation practice. Featuring helpful checklists, procedural steps, provocative questions that invite readers to explore their own theoretical assumptions, and practical exercises, the book provides concrete guidance for conducting large- and small-scale evaluations. Numerous sample studies—many with reflective commentary from the evaluators—reveal the process through which an evaluator incorporates a paradigm into an actual research project. The book shows how theory informs methodological choices (the specifics of planning, implementing, and using evaluations). It offers balanced coverage of quantitative, qualitative, and mixed methods approaches. Useful pedagogical features include: *Examples of large- and small-scale evaluations from multiple disciplines. *Beginning-of-chapter reflection questions that set the stage for the material covered. *"Extending your thinking" questions and practical activities that help readers apply particular theoretical paradigms in their own evaluation projects. *Relevant Web links, including pathways to more details about sampling, data collection, and analysis. *Boxes offering a closer look at key evaluation concepts and additional studies. *Checklists for readers to determine if they have followed recommended practice.
Book Synopsis A Short Introduction to Counselling Psychology by : Vanja Orlans
Download or read book A Short Introduction to Counselling Psychology written by Vanja Orlans and published by SAGE Publications Ltd. This book was released on 2008-12-19 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Covering key issues in the development of counselling psychology, this text is ideal for psychologists considering entering counselling psychology training or those who have already started on this path" Stephen Palmer, Professor of Psychology, City University. "This book provides a thorough yet accessible introduction to counselling psychology. Written in a highly engaging manner, this timely publication will undoubtedly provide an invaluable resource to all that read it" Ewan Gillon, Senior Lecturer in Counselling Psychology, Glasgow Caledonian University A Short Introduction to Counselling Psychology brings together a wide range of information on the theory and practice of counselling psychology, written through the lens of direct practitioner experience and incorporating a global perspective. The authors offer views on cutting-edge issues in counselling psychology, discussing: - the social and historical context - philosophical considerations - the professional knowledge base - training requirements and paths, careers and practice - the tasks, challenges and debates that practitioners deal with in different settings. This accessible introduction is of special interest to students considering a career in counselling psychology, and to professionals involved in the training and supervision of counselling psychologists. As both an up-to-date review of professional developments in relation to the field of counselling psychology and also more broadly, senior practitioners should welcome this resource as a reference covering all aspects of the present professional setting.
Book Synopsis Routledge Handbook of Physical Education Pedagogies by : Catherine D. Ennis
Download or read book Routledge Handbook of Physical Education Pedagogies written by Catherine D. Ennis and published by Routledge. This book was released on 2016-08-05 with total page 1003 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first fully comprehensive review of theory, research and practice in physical education to be published in over a decade, this handbook represents an essential, evidence-based guide for all students, researchers and practitioners working in PE. Showcasing the latest research and theoretical work, it offers important insights into effective curriculum management, student learning, teaching and teacher development across a variety of learning environments. This handbook not only examines the methods, influences and contexts of physical education in schools, but also discusses the implications for professional practice. It includes both the traditional and the transformative, spanning physical education pedagogies from the local to the international. It also explores key questions and analysis techniques used in PE research, illuminating the links between theory and practice. Its nine sections cover a wide range of topics including: curriculum theory, development, policy and reform transformative pedagogies and adapted physical activity educating teachers and analysing teaching the role of student and teacher cognition achievement motivation. Offering an unprecedented wealth of material, the Routledge Handbook of Physical Education Pedagogies is an essential reference for any undergraduate or postgraduate degree programme in physical education or sports coaching, and any teacher training course with a physical education element.
Book Synopsis Policy and Practice in Science Education for the Gifted by : Manabu Sumida
Download or read book Policy and Practice in Science Education for the Gifted written by Manabu Sumida and published by Routledge. This book was released on 2017-03-16 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: Gifted education has come to be regarded as a key national programme in many coutnries, and gifted education in science disciplines is now being recognised to be of major importance for economic and technological development. Despite these initiatives and developments internationally, there are very few discussions on gifted education in science drawing upon practices and experiences in different national contexts. In support of an international dialogue between researchers and practitioners, often working within isolated traditions, this book offers information on key influential approaches to science education for gifted learners and surveys current policy and practice from a diverse range of educational contexts. The volume offers an informative introduction for those new to studying gifted science education, as well as supporting the development of the field by offering examples of critical thinking about key issues, and accounts of the influences at work within education systems and the practical complexities of providing science education for the gifted. The contributions draw upon a variety of research approaches to offer insights into the constraints and affordancxes of working within particular policy contexts, and the strengths and challenges inherent in different approaches to practice. Chapters include: Teaching science to the gifted in English state schools: locating a compromised 'gifted & talented' policy within its systemic context Models of education for science talented adolescents in the United States: Past, present, and likely future trends Navigating the shifting terrain between policy and practice for gifted learners in Tanzania Science education for female indigenous gifted students in the Mexican context Gifted Science Education in the Context of Japanese Standardization This book will appeal to scholars, practitioners and policy makers who are in the field of gifted science education.
Book Synopsis Sport Psychology: The Basics by : Rhonda Cohen
Download or read book Sport Psychology: The Basics written by Rhonda Cohen and published by Bloomsbury Publishing. This book was released on 2016-02-25 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: This comprehensive and accessible resource can be used as textbook or a self-help book and is aimed at students, athletes, coaches, sport scientists or indeed any-one looking to enhance their performance, whatever their sport or activity. The psychological concepts may even be useful for those working in business. It covers the key topics in sport psychology, but also addresses current issues such as talent identification, mental toughness, risk taking, stress management, mindfulness, gender issues, sporting injuries and the use of social media. It contains examples from a multitude of sports around the world, and new developing areas such as strength and conditioning, extreme sport and combat sports. Recognising the importance for the reader to fully understand the topic in order to apply this knowledge, the book provides a comprehensive overview of each topic before presenting practical applications as well as recommending online resources. Every chapter focuses around answering key questions integral to each topic within sports psychology, helping the reader to progress in their understanding of the theory and learning how to apply it. Sports used as examples include: football (soccer), rugby, tennis, cricket, motorsport, swimming, winter sports, weight lifting, martial arts, athletics (track & field), baseball, and American football.
Book Synopsis Guide to International Transfer Pricing by : Dr A. Michael Heimert
Download or read book Guide to International Transfer Pricing written by Dr A. Michael Heimert and published by Kluwer Law International B.V.. This book was released on 2018-10-26 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt: The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.
Download or read book The Peace Psychology Bulletin written by and published by . This book was released on 1992 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Sport Cyberpsychology by : Olivia A. Hurley
Download or read book Sport Cyberpsychology written by Olivia A. Hurley and published by Routledge. This book was released on 2018-03-05 with total page 231 pages. Available in PDF, EPUB and Kindle. Book excerpt: Sport Cyberpsychology is the first book devoted to assessing the influence of technology on human interaction, behaviour and mental health in a sport context, gathering research on the use of technology and the Internet by athletes, coaches and sport science support staff. The book identifies the potential impact of technology on athletes' mental preparation for competition, as well as the role of technology in improving performance. It explores the use of technology by athletes and sport organisations for social interaction, while also considering the 'darker' side of athletes’ Internet use. It covers topics including: the role of GPS, gaming and virtual reality in training and injury recovery the use of social media by athletes and sport organisations the psychology of self-presentation and brand management, as well as issues of online privacy the use of technology by other elite groups, such as military and medical personnel, and non-elite sportspeople cyberbullying and online harassment of athletes online gambling and athletes' mental health in relation to their online activities virtual learning environments and the educational opportunities the online world can offer athletes Accessibly written, with a companion website featuring lecture slides, reading lists, video links and suggested social media accounts, Sport Cyberpsychology offers a complete resource for students and instructors alike. It is important reading for any students of sport psychology, sport coaching or sport media, as well as coaches, athletes and sport science support staff.
Book Synopsis Counselling Psychology by : David Murphy
Download or read book Counselling Psychology written by David Murphy and published by John Wiley & Sons. This book was released on 2017-06-30 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: A complete introduction to the theory and practice of contemporary counselling psychology An excellent resource for students at undergraduate or graduate level, Counselling Psychology: A Textbook for Study and Practice provides valuable insights into the key issues associated with theory and practice in this field. The contributors represent a diverse array of approaches, reflecting the rich diversity within the area, and care is taken to avoid favouring any one approach. The book begins with an overview of the historical and philosophical foundations of counselling psychology, before taking a detailed look at major therapeutic approaches and exploring issues associated with specific client populations, ethics, research design, and more. In particular, the text seeks to explain how counselling psychology differs from and informs other areas of contemporary applied psychology. The result is an engaging balance of the personal and academically rigorous, presented in a highly accessible format. • An authoritative introduction to and key issues involved with the theory and practice of counselling psychology for students and practitioners at all levels • Considers all major approaches to psychotherapy including existential, person-centered experiential, psychodynamic, and cognitive-behavioural • Explores issues commonly encountered when working with specific client groups including children, people with intellectual disabilities, and emergency trauma victims
Author :United States. Congress. House. Committee on Small Business. Subcommittee on Export Opportunities and Special Small Business Problems Publisher : ISBN 13 : Total Pages :548 pages Book Rating :4.0/5 (1 download)
Book Synopsis Oversight of Regulatory Flexibility Act by : United States. Congress. House. Committee on Small Business. Subcommittee on Export Opportunities and Special Small Business Problems
Download or read book Oversight of Regulatory Flexibility Act written by United States. Congress. House. Committee on Small Business. Subcommittee on Export Opportunities and Special Small Business Problems and published by . This book was released on 1983 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt:
