Concept And Implementation Of Cfc Legislation

Download Concept And Implementation Of Cfc Legislation full books in PDF, epub, and Kindle. Read online Concept And Implementation Of Cfc Legislation ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!

Concept and Implementation of CFC Legislation

Author : Nathalie Bravo
Publisher : Linde Verlag GmbH
ISBN 13 : 3709411580
Total Pages : 536 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Concept and Implementation of CFC Legislation by : Nathalie Bravo

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

Concept and Implementation of CFC Legislation

Author : Alexandra Miladinovic
Publisher :
ISBN 13 : 9783707344059
Total Pages : pages
Book Rating : 4.3/5 (44 download)

DOWNLOAD NOW!

Book Synopsis Concept and Implementation of CFC Legislation by : Alexandra Miladinovic

Download or read book Concept and Implementation of CFC Legislation written by Alexandra Miladinovic and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Controlled Foreign Company Legislation

Author : Organisation for Economic Co-operation and Development
Publisher : OECD
ISBN 13 :
Total Pages : 172 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!

Book Synopsis Controlled Foreign Company Legislation by : Organisation for Economic Co-operation and Development

Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.

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

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

DOWNLOAD NOW!

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.

Justice, Equality and Tax Law

Author : Nevia Čičin-Šain
Publisher : Linde Verlag GmbH
ISBN 13 : 3709412323
Total Pages : 638 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

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.

OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264241159
Total Pages : 72 pages
Book Rating : 4.2/5 (642 download)

DOWNLOAD NOW!

Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 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 3.

Limiting Base Erosion

Author : Erik Pinetz
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408814
Total Pages : 568 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Limiting Base Erosion by : Erik Pinetz

Download or read book Limiting Base Erosion written by Erik Pinetz and published by Linde Verlag GmbH. This book was released on 2017-08-30 with total page 568 pages. Available in PDF, EPUB and Kindle. Book excerpt: Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.

Harmful Tax Competition An Emerging Global Issue

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

DOWNLOAD NOW!

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.

CFC Legislation, Tax Treaties and EC Law

Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041122842
Total Pages : 658 pages
Book Rating : 4.0/5 (411 download)

DOWNLOAD NOW!

Book Synopsis CFC Legislation, Tax Treaties and EC Law by : Michael Lang

Download or read book CFC Legislation, Tax Treaties and EC Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.

Multilateral Cooperation in Tax Law

Author : Martin Klokar
Publisher : Linde Verlag GmbH
ISBN 13 : 3709412978
Total Pages : 415 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Multilateral Cooperation in Tax Law by : Martin Klokar

Download or read book Multilateral Cooperation in Tax Law written by Martin Klokar and published by Linde Verlag GmbH. This book was released on 2023-10-03 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021–23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.

Tax Treaty Case Law around the Globe 2023

Author : Georg Kofler
Publisher : Linde Verlag GmbH
ISBN 13 : 3709413400
Total Pages : 336 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Tax Treaty Case Law around the Globe 2023 by : Georg Kofler

Download or read book Tax Treaty Case Law around the Globe 2023 written by Georg Kofler and published by Linde Verlag GmbH. This book was released on 2024-04-17 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 29 most important tax treaty cases that were decided around the world in 2022. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2023 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.

Tax Treaty Case Law around the Globe 2022

Author : Eric Kemmeren
Publisher : Linde Verlag GmbH
ISBN 13 : 3709413281
Total Pages : 480 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Tax Treaty Case Law around the Globe 2022 by : Eric Kemmeren

Download or read book Tax Treaty Case Law around the Globe 2022 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2023-11-29 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

Tax and Technology

Author : Annika Streicher
Publisher : Linde Verlag GmbH
ISBN 13 : 3709413001
Total Pages : 533 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Tax and Technology by : Annika Streicher

Download or read book Tax and Technology written by Annika Streicher and published by Linde Verlag GmbH. This book was released on 2023-10-13 with total page 533 pages. Available in PDF, EPUB and Kindle. Book excerpt: The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.

Chinese Tax Law and International Treaties

Author : Lorenzo Riccardi
Publisher : Springer Science & Business Media
ISBN 13 : 3319002759
Total Pages : 278 pages
Book Rating : 4.3/5 (19 download)

DOWNLOAD NOW!

Book Synopsis Chinese Tax Law and International Treaties by : Lorenzo Riccardi

Download or read book Chinese Tax Law and International Treaties written by Lorenzo Riccardi and published by Springer Science & Business Media. This book was released on 2013-05-30 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: The People’s Republic of China’s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation’s rise to the world’s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China’s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China’s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China’s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis. Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.

Prohibition of Abuse of Law

Author : Rita de la Feria
Publisher : Bloomsbury Publishing
ISBN 13 : 1847317855
Total Pages : 532 pages
Book Rating : 4.8/5 (473 download)

DOWNLOAD NOW!

Book Synopsis Prohibition of Abuse of Law by : Rita de la Feria

Download or read book Prohibition of Abuse of Law written by Rita de la Feria and published by Bloomsbury Publishing. This book was released on 2011-06-09 with total page 532 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Court of Justice has been alluding to 'abuse and abusive practices' for more than thirty years, but for a long time the significance of these references has been unclear. Few lawyers examined the case law, and those who did doubted whether it had led to the development of a legal principle. Within the last few years there has been a radical change of attitude, largely due to the development by the Court of an abuse test and its application within the field of taxation. In this book, academics and practitioners from all over Europe discuss the development of the Court's approach to abuse of law across the whole spectrum of European Union law, analysing the case-law from the 1970s to the present day and exploring the consequences of the introduction of the newly designated 'principle of prohibition of abuse of law' for the development of the laws of the EU and those of the Member States.

Ukraine

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
ISBN 13 : 1513521055
Total Pages : 79 pages
Book Rating : 4.5/5 (135 download)

DOWNLOAD NOW!

Book Synopsis Ukraine by : International Monetary Fund. Fiscal Affairs Dept.

Download or read book Ukraine written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2019-11-22 with total page 79 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Technical Assistance report focuses on Ukraine’s distributed profit tax, voluntary disclosure of assets, and Base Erosion and Profit Shifting Work Program implementation. The recommendations largely favor simplifying rules, improving the definition of basic concepts, eliminating potential loopholes, and adhering more closely to international standards in some cases. Thus, for the sake of simplification, the report recommends that Controlled Foreign Corporation rules should apply to the ‘first onshore’ person rather than having to trace them back to the ultimate beneficial owner in Ukraine. Also, it recommends that the proposed interest deduction limitation should eliminate the carry-forward currently permitted, limit deductions to net interest expense and exempt the financial sector from this limitation. Some key definitions can be improved too. The report suggests that if there is an urgent need to promote private investments, the accelerated depreciation tool should be applied for plant and machinery and structures housing them for say another five years.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

Download OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report PDF Online Free

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264241132
Total Pages : 456 pages
Book Rating : 4.2/5 (642 download)

DOWNLOAD NOW!

Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 456 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 2.