Classifying Entities and the Meaning of 'Tax Transparency'

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403537442
Total Pages : 414 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Classifying Entities and the Meaning of 'Tax Transparency' by : Michael McGowan

Download or read book Classifying Entities and the Meaning of 'Tax Transparency' written by Michael McGowan and published by Kluwer Law International B.V.. This book was released on 2023-01-10 with total page 414 pages. Available in PDF, EPUB and Kindle. Book excerpt: Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.

Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions, Second Edition

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Author :
Publisher : OECD Publishing
ISBN 13 : 9789264107236
Total Pages : 228 pages
Book Rating : 4.1/5 (72 download)

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Book Synopsis Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions, Second Edition by : OECD

Download or read book Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions, Second Edition written by OECD and published by OECD Publishing. This book was released on 2011-06-27 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: This handbook provides guidance for the assessment teams and the reviewed jurisdictions that are participating in the Global Forum on Transparency and Exchange of Information for Tax Purposes (the “Global Forum”) peer reviews and non-member reviews.

Tax Law Design and Drafting, Volume 1

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Publisher : International Monetary Fund
ISBN 13 : 9781557755872
Total Pages : 534 pages
Book Rating : 4.7/5 (558 download)

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Book Synopsis Tax Law Design and Drafting, Volume 1 by : Mr.Victor Thuronyi

Download or read book Tax Law Design and Drafting, Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition

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Publisher : OECD Publishing
ISBN 13 : 9264267999
Total Pages : 324 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition by : OECD

Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

A Beneficial Ownership Implementation Toolkit

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Author :
Publisher : Inter-American Development Bank
ISBN 13 :
Total Pages : 51 pages
Book Rating : 4./5 ( download)

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Book Synopsis A Beneficial Ownership Implementation Toolkit by : Organization for Economic Cooperation and Development

Download or read book A Beneficial Ownership Implementation Toolkit written by Organization for Economic Cooperation and Development and published by Inter-American Development Bank. This book was released on 2019-05-21 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2016, the G20 called on the FATF and the Global Forum to propose ways to improve the implementation of the international standards on transparency, including on the availability of beneficial ownership information, and its international exchange. The Global Forum developed a framework of proposed actions to answer that call, including a plan to facilitate effective implementation through examples of good implementation and technical assistance. This toolkit is in furtherance of the Global Forum’s commitment to support countries’ effective implementation. It is intended to help jurisdictions to develop an understanding of the beneficial ownership concepts contained in the international standards of transparency and exchange of information, and for use in conjunction with technical assistance seminars. It will support policy and implementation discussions in conjunction with capacity building workshops and technical assistance activities carried out by the Global Forum Secretariat as well as other supporting international organizations.

Transparency in Government Operations

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Publisher : International Monetary Fund
ISBN 13 : 155775697X
Total Pages : 50 pages
Book Rating : 4.5/5 (577 download)

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Book Synopsis Transparency in Government Operations by : Mr.J. D. Craig

Download or read book Transparency in Government Operations written by Mr.J. D. Craig and published by International Monetary Fund. This book was released on 1998-02-03 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transparency in government operations is widely regarded as an important precondition for macroeconomic fiscal sustainability, good governance, and overall fiscal rectitude. Notably, the Interim Committee, at its April and September 1996 meetings, stressed the need for greater fiscal transparency. Prompted by these concerns, this paper represents a first attempt to address many of the aspects of transparency in government operations. It provides an overview of major issues in fiscal transparency and examines the IMF's role in promoting transparency in government operations.

Harmful Tax Competition An Emerging Global Issue

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Publisher : OECD Publishing
ISBN 13 : 9264162941
Total Pages : 82 pages
Book Rating : 4.2/5 (641 download)

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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.

Action Plan on Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264202714
Total Pages : 44 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : OECD

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

International Commercial Tax

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Publisher : Cambridge University Press
ISBN 13 : 9780521853118
Total Pages : 520 pages
Book Rating : 4.8/5 (531 download)

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Book Synopsis International Commercial Tax by : Peter Harris

Download or read book International Commercial Tax written by Peter Harris and published by Cambridge University Press. This book was released on 2010-07-22 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.

Double non-taxation and the use of hybrid entities

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 940354676X
Total Pages : 531 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Double non-taxation and the use of hybrid entities by : Leopoldo Parada

Download or read book Double non-taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.

The Economics of Tax Policy

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Author :
Publisher : Oxford University Press
ISBN 13 : 0190619732
Total Pages : 352 pages
Book Rating : 4.1/5 (96 download)

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Book Synopsis The Economics of Tax Policy by : Alan J. Auerbach

Download or read book The Economics of Tax Policy written by Alan J. Auerbach and published by Oxford University Press. This book was released on 2017-02-15 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: The debates about the what, who, and how of tax policy are at the core of politics, policy, and economics. The Economics of Tax Policy provides a straightforward overview of recent research in the economics of taxation. Tax policies generate considerable debate among the public, policymakers, and scholars. These disputes have grown more heated in the United States as the incomes of the wealthiest 1 percent and the rest of the population continue to diverge. This important volume enhances understanding of the implications of taxation on behavior and social outcomes by having leading scholars evaluate key topics in tax policy. These include how changes to the individual income tax affect long-term economic growth; the challenges of tax administration, compliance, and enforcement; and environmental taxation and its effects on tax revenue, pollution emissions, economic efficiency, and income distribution. Also explored are tax expenditures, which are subsidy programs in the form of tax deductions, exclusions, credits, or favorable rates; how college attendance is influenced by tax credits and deductions for tuition and fees, tax-advantaged college savings plans, and student loan interest deductions; and how tax policy toward low-income families takes a number of forms with different distributional effects. Among the most contentious issues explored are influences of capital gains and estate taxation on the long term concentration of wealth; the interaction of tax policy and retirement savings and how policy can "nudge" improved planning for retirement; and how the reform of corporate and business taxation is central to current tax policy debates in the United States. By providing overviews of recent advances in thinking about how taxes relate to behavior and social goals, The Economics of Tax Policy helps inform the debate.

Tax Havens

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Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (15 download)

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Book Synopsis Tax Havens by : Jane Gravelle

Download or read book Tax Havens written by Jane Gravelle and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report discusses the State of the Union address, which is a communication between the President and Congress in which the chief executive reports on the current conditions of the United States and provides policy proposals for the upcoming legislative year.

OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241485
Total Pages : 72 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 13.

Tribal Business Structure Handbook

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Publisher :
ISBN 13 : 9780692057650
Total Pages : pages
Book Rating : 4.0/5 (576 download)

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Book Synopsis Tribal Business Structure Handbook by : Karen J. Atkinson

Download or read book Tribal Business Structure Handbook written by Karen J. Atkinson and published by . This book was released on 2009 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive resource on the formation of tribal business entities. Hailed in Indian Country Today as offering "one-stop knowledge on business structuring," the Handbook reviews each type of tribal business entity from the perspective of sovereign immunity and legal liability, corporate formation and governance, federal tax consequences and eligibility for special financing. Covers governmental entities and common forms of business structures.

Government Finance Statistics Manual 2014

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Publisher : International Monetary Fund
ISBN 13 : 1498379214
Total Pages : 470 pages
Book Rating : 4.4/5 (983 download)

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Book Synopsis Government Finance Statistics Manual 2014 by : Mrs.Sage De Clerck

Download or read book Government Finance Statistics Manual 2014 written by Mrs.Sage De Clerck and published by International Monetary Fund. This book was released on 2015-03-10 with total page 470 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2007–09 international financial crisis underscored the importance of reliable and timely statistics on the general government and public sectors. Government finance statistics are a basis for fiscal analysis and they play a vital role in developing and monitoring sound fiscal programs and in conducting surveillance of economic policies. The Government Finance Statistics Manual 2014 represents a major step forward in clarifying the standards for compiling and presenting fiscal statistics and strengthens the worldwide effort to improve public sector reporting and transparency.

International Classification of Non-Tariff Measures 2019

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Author :
Publisher : United Nations
ISBN 13 : 921004200X
Total Pages : 96 pages
Book Rating : 4.2/5 (1 download)

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Book Synopsis International Classification of Non-Tariff Measures 2019 by : United Nations

Download or read book International Classification of Non-Tariff Measures 2019 written by United Nations and published by United Nations. This book was released on 2019-10-14 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt: Non-tariff measures are generally defined as policy measures other than ordinary customs tariffs that can potentially have an economic effect on international trade in goods, changing quantities traded, or prices or both. Since this definition is broad, a detailed classification is of critical importance so as to better identify and distinguish among the various forms of non-tariff measures. The classification of non-tariff measures presented here is a taxonomy of all those measures considered relevant in international trade today. It builds on an old UNCTAD classification known as the Coding System of Trade Control Measures and was developed by several international organizations forming what is called the MAST group (Multi-Agency Support Team) set up to support the Group of Eminent Persons on Non-tariff Barriers established by the Secretary General of UNCTAD in 2006. The MAST team discussed and proposed this classification, and is composed of: FAO, IMF, ITC, OECD, UNCTAD, UNIDO, World Bank and WTO. The classification is seen as evolving and should adapt to the reality of international trade and data collection needs.

The Puppet Masters

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Publisher : World Bank Publications
ISBN 13 : 0821388967
Total Pages : 230 pages
Book Rating : 4.8/5 (213 download)

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Book Synopsis The Puppet Masters by : Emile van der Does de Willebois

Download or read book The Puppet Masters written by Emile van der Does de Willebois and published by World Bank Publications. This book was released on 2011-11-01 with total page 230 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report examines the use of these entities in nearly all cases of corruption. It builds upon case law, interviews with investigators, corporate registries and financial institutions and a 'mystery shopping' exercise to provide evidence of this criminal practice.