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Characterisation And Taxation Of Cross Border Pipelines
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Book Synopsis Characterisation and Taxation of Cross-border Pipelines by : Knut Olsen
Download or read book Characterisation and Taxation of Cross-border Pipelines written by Knut Olsen and published by IBFD. This book was released on 2012 with total page 285 pages. Available in PDF, EPUB and Kindle. Book excerpt: Characterisation and Taxation of Cross-Border Pipelines provides a comprehensive analysis of the issues related to the taxation of cross-border pipelines. It offers solutions to the various tax issues that a cross-border pipeline might raise. The book concludes by recommending changes to the OECD Model Tax Treaty and its Commentaries to reduce uncertainty, avoid double taxation or less than a single taxation, and establish a more common international approach for the characterisation and taxation of cross-border pipelines and their allocation."--Publisher description.
Book Synopsis International Taxation of Energy Production and Distribution by : John Abrahamson
Download or read book International Taxation of Energy Production and Distribution written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2018-04-20 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.
Book Synopsis Justice, Equality and Tax Law by : Nevia Čičin-Šain
Download or read book Justice, Equality and Tax Law written by Nevia Čičin-Šain and published by Linde Verlag GmbH. This book was released on 2022-10-05 with total page 638 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.
Book Synopsis Permanent Establishments by : Ekkehart Reimer
Download or read book Permanent Establishments written by Ekkehart Reimer and published by Kluwer Law International B.V.. This book was released on 2018-06-07 with total page 850 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
Book Synopsis International Taxation and the Extractive Industries by : Philip Daniel
Download or read book International Taxation and the Extractive Industries written by Philip Daniel and published by Taylor & Francis. This book was released on 2016-09-23 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics.
Book Synopsis Removing Tax Barriers to China's Belt and Road Initiative by : Michael Lang
Download or read book Removing Tax Barriers to China's Belt and Road Initiative written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2018-11-27 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since its announcement in 2013, the Belt and Road Initiative (BRI), also known as the New Silk Road, has gradually gained international recognition. The project requires not only extensive investment in infrastructure and transportation but also an acceleration of the internationalization of multinationals and supply chains in Belt and Road countries. The project will, hopefully, lead governments and businesses in countries along the Belt and Road to compete, adopt best practices and improve transparency. The BRI marks a national push by China to increase economic links to Southeast Asia, Central Asia, Russia, the Baltic region (Central and Eastern Europe), Africa and Latin America, which will have major consequences for the way that tax systems interact. Emerging from the research conducted by the WU Global Tax Policy Center in cooperation with several Chinese universities, this book offers fourteen policy-relevant research papers prepared by international experts on the following issues: • The New Silk Road: Will Tax Be a Facilitator or a Barrier? • Neo-BEPS: China’s Prescription for International Tax Reform Embodying the Rationality of the Belt & Road Initiative; • International Taxation Coordination under China’s Belt and Road Strategy; • Tax Issues in the Main Belt and Road Countries and Industries of China’s Outward Foreign Direct Investment; • Preferential Arrangements under Chinese Tax Treaties with Belt and Road Countries and Disputes Regarding Their Applicability; • Tax Planning by Going-Global Enterprises for Cross-Border Earnings: Observations Based on Belt and Road Countries; • International Taxation Issues under the Belt and Road Initiative: Corporate Income Tax Laws and Tax Treaties; • Financial and Tax Operations in the Five Central Asian Countries; • The Role of Border-Crossing Procedures in the Transportation of Goods along the New Silk Road; • Transfer Pricing Issues Related to the Belt and Road Initiative; • Tax Treaties between Belt and Road Countries; • VAT Challenges in the Belt and Road Initiative; • Global Tax Policy Post-BEPS and the Perils of the Silk Road; and • Creating a Positive Tax Climate for Complex Multijurisdictional Investment Projects. Outcomes presented in the book consist of findings presented during Tax Policy Forum on the Belt and Road Initiative held on 12–13 June 2017 in Beijing, jointly organized with Peking University Tax Law Center and the Central University of Finance and Economics, Beijing. These papers also formed the basis for input by WU Global Tax Policy Center at the first meeting of The Belt and Road Initiative Tax Cooperation Conference (BRITCC) held in Astana on 14–16 May 2018, in which it was agreed to establish a permanent forum to examine the tax issues that arise from the BRI. The WU Global Tax Policy Center will continue to provide inputs to this forum.
Book Synopsis Federal Taxation of Oil and Gas Transactions by : Leland E. Fiske
Download or read book Federal Taxation of Oil and Gas Transactions written by Leland E. Fiske and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Taxation of Cross-border Leasing Income by : Amar Mehta
Download or read book International Taxation of Cross-border Leasing Income written by Amar Mehta and published by IBFD. This book was released on 2005 with total page 307 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.
Book Synopsis International Energy Law by : Mohammad Naseem
Download or read book International Energy Law written by Mohammad Naseem and published by Kluwer Law International B.V.. This book was released on 2021-04-20 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: Derived from the renowned multi-volume International Encyclopaedia of Laws, this book provides a systematic approach to legislation and legal practice concerning energy resources and production in International Energy Law. The book describes the administrative organization, regulatory framework, and relevant case law pertaining to the development, application, and use of such forms of energy as electricity, gas, petroleum, and coal, with attention as needed to the pervasive legal effects of competition law, environmental law, and tax law. A general introduction covers the geography of energy resources, sources and basic principles of energy law, and the relevant governmental institutions. Then follows a detailed description of specific legislation and regulation affecting such factors as documentation, undertakings, facilities, storage, pricing, procurement and sales, transportation, transmission, distribution, and supply of each form of energy. Case law, intergovernmental cooperation agreements, and interactions with environmental, tax, and competition law are explained. Its succinct yet scholarly nature, as well as the practical quality of the information it provides, make this book a valuable resource for energy sector policymakers and energy firm counsel handling cases affecting International Energy Law. It will also be welcomed by researchers and academics for its contribution to the study of a complex field that today stands at the foreground of comparative law.
Book Synopsis Crossing African Borders by : Cristina Udelsmann Rodrigues
Download or read book Crossing African Borders written by Cristina Udelsmann Rodrigues and published by Centro de Estudos Internacionais. This book was released on 2017-08-04 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is one of the results of a conference organised in Lisbon in 2011 on the theme of African borders and their relationships with migration and mobility. The selected papers are a sample of the diverse perspectives on the general theme presented at the meeting. The African Borderlands Research Network (ABORNE) promoted this event, allowing a substantial number of its members to exchange results of ongoing and long-term research. The Fundação para a Ciência e a Tecnologia (Portugal) funded the research project Borders and Identity in Africa (PTDC/AFR/098339/2008) which prepared this publication.
Book Synopsis Cross-border Oil and Gas Pipelines and the Role of the Transit Country by : E. Omonbude
Download or read book Cross-border Oil and Gas Pipelines and the Role of the Transit Country written by E. Omonbude and published by Springer. This book was released on 2016-01-12 with total page 259 pages. Available in PDF, EPUB and Kindle. Book excerpt: With frequent discoveries of energy resources in remote and undeveloped areas, the importance of transnational oil and gas pipelines is set to grow ever more prominent. This study dissects the diplomacy and bargaining power of the transit country and the shifting economic relations involved in cross-border energy transportation.
Book Synopsis International Taxation of Cloud Computing by : Alexander Weisser
Download or read book International Taxation of Cloud Computing written by Alexander Weisser and published by Éditions juridiques libres / Freier juristischer Verlag. This book was released on 2020-10-07 with total page 594 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profit is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.
Book Synopsis Energy and Environmental Project Finance Law and Taxation by : Andrea Kramer
Download or read book Energy and Environmental Project Finance Law and Taxation written by Andrea Kramer and published by . This book was released on 2010-12-09 with total page 1030 pages. Available in PDF, EPUB and Kindle. Book excerpt: Energy and Environmental Project Finance Law and Taxation: New Investment Techniques provides practitioners with a useful and comprehensive discussion of energy and environmental project finance as it is developing and where it is going in light of new legal and tax rules. This is the first time that internationally recognized lawyers and economists share their knowledge, expertise, and insights in this important and growing industry. Energy and Environmental Project Finance Law and Taxation examines cutting edge techniques and analyses the recent tax and legal developments coming out of Washington, all of which are revolutionizing the investment in and financing of energy and environmental projects. Written for practitioners and laymen alike, Energy and Environmental Project Finance Law and Taxation arms the reader with crucial knowledge about structuring and financing conventional, renewable, green financing, and alternative energy projects. It addresses carbon financing, green power, and traditional and new technologies, including nuclear power, wind, photovoltaic, solar, geothermal, biomass, and the new generation of nuclear power. This book also addresses the risks involved in structuring and financing these new technologies; ways to hedge these risks; and how to monetize the tax credits available for renewable energy projects.
Book Synopsis A Guide to the European VAT Directives by : Ben Terra
Download or read book A Guide to the European VAT Directives written by Ben Terra and published by IBFD. This book was released on 2012 with total page 1317 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Cross-Border Management by : Rongxing Guo
Download or read book Cross-Border Management written by Rongxing Guo and published by Springer. This book was released on 2015-01-05 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents a new approach to management in an increasingly interactive world. In this context, the use of the word “new” has two meanings. The first relates to a new definition of borders (which are natural, institutional, functional, or mixed); the second concerns the fact that the book applies (and, where necessary, develops) analytical tools, methods and models that are different from those used in other similar books. The objectives of this book are: to clarify whether existing management theories and methods can be effectively applied in an entity (which can be defined as a sovereign country, a region, a community, a culture, or a firm) as the latter increasingly interacts with the rest of the world; to develop qualitative and quantitative methods to help leaders make optimal decisions for their entity and, at the same time, to maximize the positive (or minimize the negative) effects of those decisions on the rest of the world; and to design workable cross-border cooperation plans and conflict-management schemes that allow policy-makers to better cope with the challenges and problems posed by our increasingly interactive world.
Download or read book Transit Troubles written by Paul Stevens and published by Chatham House Publishers. This book was released on 2009 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: Any reading of the history of transit oil and gas pipelines suggests a tendency to produce conflict and disagreement, often resulting in the cessation of throughput, sometimes for a short period and sometimes for longer. It is tempting to attribute this to bad political relations between neighbours. This is certainly part of the story, but also important is the nature of the 'transit terms'--tariffs and offtake terms--whereby transit countries are rewarded for allowing transit. Put simply, the trouble with transit pipelines has a significant economic basis. This report addresses three key questions: Why will oil and gas transit pipelines become more important to global energy markets in the future? Why has the history of such pipelines been littered with conflict between the various parties? What might be done to improve this record in the future and make transit pipelines less troublesome?--Publisher description.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2010 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2010 written by OECD and published by OECD Publishing. This book was released on 2010-08-17 with total page 470 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the eighth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the full text of the Model Tax Convention on Income and on Capital as adopted by the OECD Council on 22 July 2010.
