Read Books Online and Download eBooks, EPub, PDF, Mobi, Kindle, Text Full Free.
Corporate Shareholder Income Taxation And Allocating Taxing Rights Between Countries
Download Corporate Shareholder Income Taxation And Allocating Taxing Rights Between Countries full books in PDF, epub, and Kindle. Read online Corporate Shareholder Income Taxation And Allocating Taxing Rights Between Countries ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
Book Synopsis Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries by : Peter Andrew Harris
Download or read book Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries written by Peter Andrew Harris and published by . This book was released on 1996 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: This ground-breaking book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, & they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies & inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms & finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing & could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation & many anti-avoidance measures would become superfluous. This extremely important book, based on prize-winning doctoral research, is destined to become a classic in the field. The acute perception & explication of theories underpinning international taxation make it essential reading.
Book Synopsis Introduction to the Law of Double Taxation Conventions by : Michael Lang
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Book Synopsis A Common Tax Base for Multinational Enterprises in the European Union by : Carsten Wendt
Download or read book A Common Tax Base for Multinational Enterprises in the European Union written by Carsten Wendt and published by Springer Science & Business Media. This book was released on 2009-04-16 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.
Book Synopsis The Role of Allocation in a Globalized Corporate Income Tax by : Mr. Jack M. Mintz
Download or read book The Role of Allocation in a Globalized Corporate Income Tax written by Mr. Jack M. Mintz and published by International Monetary Fund. This book was released on 1998-09-01 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the merits and limitations of allocation methods for attributing income to different jurisdictions according to formulas measuring business activity. Such methods are being used as part of transfer pricing regimes and are likely to be enhanced over time. Whatever international arrangements develop in the future, there is a role for new institutions to improve cooperative discussions among governments.
Book Synopsis Why Corporate Taxation Should Mean Source Taxation by : Luzius U. Cavelti
Download or read book Why Corporate Taxation Should Mean Source Taxation written by Luzius U. Cavelti and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the "country of source". This article questions separate taxation based on this distinction between the country of residence and the country of source. It argues for a departure from the traditional international allocation of the right to tax corporate income and suggests that a corporate entity should instead pay income tax exclusively to the countries in which it has relevant business activities. In other words, this article advocates a "source-based corporate income tax", meaning the global allocation of corporate income based on the source of income. Moreover, in examining the question of where business activities of multinational corporations effectively take place, this article describes criteria for determining source countries. Furthermore, it offers a method for formulary apportionment of corporate income between those countries in which a given multinational corporation generates income. The article argues that source taxation of corporate income would be coherent with the economic nature of corporate income taxation. Source taxation of corporate income would also make the arbitrary concept of corporate residence irrelevant, and it would allow the outdated legal concept of permanent establishment to be abolished. This article takes an interdisciplinary approach to argue from both legal and economic perspectives. It adds to the body of literature that discusses how countries should tax corporate entities doing business across national borders. It also contributes to the ongoing debate about the OECD's recent controversial efforts to prevent corporations shifting profits between countries to minimize their exposure to national tax systems (base erosion and profit sharing, or BEPS).Full-text Paper.
Book Synopsis Landmark Decisions of the ECJ in Direct Taxation by : Werner Haslehner
Download or read book Landmark Decisions of the ECJ in Direct Taxation written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2015-10-28 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: Every professional dealing with taxation in the European Union will greatly appreciate this extraordinarily useful book. Based on a high-level conference held at the University of Luxembourg in 2014, the book presents detailed expert summaries and analyses of landmark ECJ decisions in direct taxation, each case a starting point for the development of a specific doctrine. The depth of the analysis, as each author charts a way through the nuances of the Court's arguments, allows the reader to gain an unparalleled understanding of changes in the relevant subsequent jurisprudence. The fundamental issues covered are the following: - taxation of non-residents in the EU context; - implications of EU fundamental freedoms in the income tax systems of the Member States; - outbound and inbound dividend taxation; - taxation of permanent establishments; - restrictions on freedom of establishment; - tax treatment of corporate exit; - abuse of taxpayers' rights; - cohesion of the tax system as an overriding factor in the public interest; - juridical double taxation arising from the exercise of overlapping powers of two or more States; - free movement of capital and third countries; and - tax treatment of non-profit organizations in the cross-border context. The book as a whole offers an incomparable critical assessment of the strengths and weaknesses of the Court's reasoning and its path through the complex field of crossborder income taxation, particularly in the area of the compatibility of national tax legislation with the fundamental freedoms, which continues to be a powerful driver for changes to existing tax laws. For legal academics, this is a unique and fundamental source of essential information and analysis. Crucially, although valuable as a 'snapshot' of the current state of EU tax law, this book will remain relevant for practitioners and policymakers as jurisprudence continues to develop over the years to come.
Book Synopsis The Taxation of Corporations and Shareholders by : Martin Norr
Download or read book The Taxation of Corporations and Shareholders written by Martin Norr and published by Springer. This book was released on 1982-08-05 with total page 236 pages. Available in PDF, EPUB and Kindle. Book excerpt: Monograph on the taxation of corporate-source income to corporations and to their shareholders with reference to the technical alternatives used today in countries with different legal systems and at different stages of development. It is designed primarily for the guidance of developing countries.
Book Synopsis Fundamentals of International Transfer Pricing in Law and Economics by : Wolfgang Schön
Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Book Synopsis International Income Taxation by : Richard Crawford Pugh
Download or read book International Income Taxation written by Richard Crawford Pugh and published by . This book was released on 1996 with total page 1446 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of U.S. Corporations Doing Business Abroad by : Alan Winston Granwell
Download or read book Taxation of U.S. Corporations Doing Business Abroad written by Alan Winston Granwell and published by . This book was released on 1996 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Taxation of Income from Foreign Investments:A Tax Study of Developing Countries by : Kibuta Ongwamuhana
Download or read book The Taxation of Income from Foreign Investments:A Tax Study of Developing Countries written by Kibuta Ongwamuhana and published by Springer. This book was released on 1991-01-30 with total page 160 pages. Available in PDF, EPUB and Kindle. Book excerpt: Summarizes the principles governing the assertion of national taxation powers, and the manner in which tax power of one nation is moderated by tax treaties so to present or mitigate the occurrence of double income taxation with emphasis to the tax concerns of developing countries.
Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Download or read book Taxing Wages 2021 written by OECD and published by OECD Publishing. This book was released on 2021-04-29 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by workers. Taxing Wages 2021 includes a special feature entitled: “Impact of COVID-19 on the Tax Wedge in OECD Countries”.
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Taxation of Corporate Groups Under Consolidation by : Antony Ting
Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by Cambridge University Press. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
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.
Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
