Corporate Taxation, Group Debt Funding and Base Erosion

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Author :
Publisher : Kluwer Law International
ISBN 13 : 9789403511702
Total Pages : 280 pages
Book Rating : 4.5/5 (117 download)

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Book Synopsis Corporate Taxation, Group Debt Funding and Base Erosion by : Gianluigi Bizioli

Download or read book Corporate Taxation, Group Debt Funding and Base Erosion written by Gianluigi Bizioli and published by Kluwer Law International. This book was released on 2020-02-07 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.

Corporate Income Taxes under Pressure

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Publisher : International Monetary Fund
ISBN 13 : 1513511777
Total Pages : 388 pages
Book Rating : 4.5/5 (135 download)

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Book Synopsis Corporate Income Taxes under Pressure by : Ruud A. de Mooij

Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

European Union Corporate Tax Law

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Publisher : Cambridge University Press
ISBN 13 : 1107354986
Total Pages : 413 pages
Book Rating : 4.1/5 (73 download)

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Book Synopsis European Union Corporate Tax Law by : Christiana HJI Panayi

Download or read book European Union Corporate Tax Law written by Christiana HJI Panayi and published by Cambridge University Press. This book was released on 2013-05-09 with total page 413 pages. Available in PDF, EPUB and Kindle. Book excerpt: How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.

Corporate Tax Policy and Incorporation in the EU

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Author :
Publisher :
ISBN 13 :
Total Pages : 44 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis Corporate Tax Policy and Incorporation in the EU by : Ruud A. de Mooij

Download or read book Corporate Tax Policy and Incorporation in the EU written by Ruud A. de Mooij and published by . This book was released on 2008 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Double Taxation Within the European Union

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Publisher :
ISBN 13 : 9789041135254
Total Pages : 0 pages
Book Rating : 4.1/5 (352 download)

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Book Synopsis Double Taxation Within the European Union by : Alexander Rust

Download or read book Double Taxation Within the European Union written by Alexander Rust and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the conclusion of tax treaties and despite the enactment of several directives, double taxation continues to occur within the EU, causing severe obstacles for cross-border trade, for the provision of services and capital, and for the free movement of persons. This book collects the expert analysis and recommendations on the following issues: the reasons for the existence (and persistence) of juridical and economic double taxation; double burdens in criminal law; constitutional limits for double taxation; the Lisbon Treaty's abolition of Article 293 EC, which had required Member States to conclude tax treaties in order to abolish double taxation; whether double taxation can be avoided by the application of the four freedoms; prospects for an EU-wide multilateral tax treaty; the proposed Common Consolidated Corporate Tax Base; and use of arbitration clauses in tax treaties.

Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income

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Author :
Publisher : Springer Science & Business Media
ISBN 13 : 3642284337
Total Pages : 130 pages
Book Rating : 4.6/5 (422 download)

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Book Synopsis Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income by : Christoph Spengel

Download or read book Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income written by Christoph Spengel and published by Springer Science & Business Media. This book was released on 2012-03-13 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt: The study conducted by the Centre of European Economic Research (ZEW), the University of Mannheim and Ernst & Young contributes to the ongoing evaluation of the proposal for a Draft Council Directive on a Common Consolidated Corporate Tax Base (CC(C)TB) released by the European Commission on March 16, 2011. For the first time, details on the determination of taxable income under the proposed Council Directive are compared to prevailing corporate tax accounting regulations in all 27 Member States, Switzerland and the US. The study presents evidence on the scope of differences and similarities between national tax accounting regulations and the Directive’s treatment in a complete, yet concise form. Based on this comprehensive comparison, it goes on to discuss remaining open questions and adjustments needed if the Directive is to be implemented in national tax law. Readers seeking a basis for taking an active part in the public debate will find a valuable source of information and a first impression of how the proposed CC(C)TB would affect corporate tax burdens in the European Union.

Corporate Profit Shifting

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Publisher :
ISBN 13 : 9781634837750
Total Pages : 171 pages
Book Rating : 4.8/5 (377 download)

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Book Synopsis Corporate Profit Shifting by : Dorian L. Peters

Download or read book Corporate Profit Shifting written by Dorian L. Peters and published by . This book was released on 2015 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.

Home State Taxation

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Publisher : IBFD
ISBN 13 : 9076078335
Total Pages : 105 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis Home State Taxation by : Sven-Olof Lodin

Download or read book Home State Taxation written by Sven-Olof Lodin and published by IBFD. This book was released on 2001 with total page 105 pages. Available in PDF, EPUB and Kindle. Book excerpt: Examines the proposal for home state taxation as a way to eliminate the principal barriers to the completion of the internal market in the corporate tax field. Includes an assessment by the IBFD of the compatibility of home state taxation with double taxation agreements, based on the OECD Model Convention.

Risk and Return for Regulated Industries

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Publisher : Academic Press
ISBN 13 : 0128125888
Total Pages : 362 pages
Book Rating : 4.1/5 (281 download)

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Book Synopsis Risk and Return for Regulated Industries by : Bente Villadsen

Download or read book Risk and Return for Regulated Industries written by Bente Villadsen and published by Academic Press. This book was released on 2017-04-27 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: Risk and Return for Regulated Industries provides a much-needed, comprehensive review of how cost of capital risk arises and can be measured, how the special risks regulated industries face affect fair return, and the challenges that regulated industries are likely to face in the future. Rather than following the trend of broad industry introductions or textbook style reviews of utility finance, it covers the topics of most interest to regulators, regulated companies, regulatory lawyers, and rate-of-return analysts in all countries. Accordingly, the book also includes case studies about various countries and discussions of the lessons international regulatory procedures can offer. - Presents a unified treatment of the regulatory principles and practices used to assess the required return on capital - Addresses current practices before exploring the ways methods play out in practice, including irregularities, shortcomings, and concerns for the future - Focuses on developed economies instead of providing a comprehensive global reviews - Foreword by Stewart C. Myers

The Impact of Globalization on International Finance and Accounting

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Publisher : Springer
ISBN 13 : 331968762X
Total Pages : 469 pages
Book Rating : 4.3/5 (196 download)

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Book Synopsis The Impact of Globalization on International Finance and Accounting by : David Procházka

Download or read book The Impact of Globalization on International Finance and Accounting written by David Procházka and published by Springer. This book was released on 2017-12-29 with total page 469 pages. Available in PDF, EPUB and Kindle. Book excerpt: This proceedings volume analyzes the impact of globalization on international financial flow as well as harmonized financial reporting. Featuring contributions presented at the 18th Annual Conference on Finance and Accounting held at the University of Economics in Prague, this book examines the economic consequences of the globalized world in the sphere of corporate and public finance, monetary systems, banking, financial reporting and management accounting. The global perspective is accompanied by local specific cases studies, including those from emerging markets. In addition, the combination of micro- and macroeconomic approaches provide insights on the behavior of all relevant stakeholders in the process and the results of dynamic pressures surrounding global capital markets and international investments. This book will serve as a useful resource for scholars and researchers, practitioners and policy makers in the fields of finance, economics and accounting.

International Company Taxation and Tax Planning

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Author :
Publisher :
ISBN 13 : 9789041145567
Total Pages : 0 pages
Book Rating : 4.1/5 (455 download)

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Book Synopsis International Company Taxation and Tax Planning by : Dieter Endres

Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

The Budget and Economic Outlook

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Author :
Publisher :
ISBN 13 :
Total Pages : 196 pages
Book Rating : 4.3/5 (243 download)

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Book Synopsis The Budget and Economic Outlook by :

Download or read book The Budget and Economic Outlook written by and published by . This book was released on 2008 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of EU VAT Law

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403523441
Total Pages : 661 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Fundamentals of EU VAT Law by : Frank Nellen

Download or read book Fundamentals of EU VAT Law written by Frank Nellen and published by Kluwer Law International B.V.. This book was released on 2020-08-19 with total page 661 pages. Available in PDF, EPUB and Kindle. Book excerpt: Parties to cross-border disputes arising anywhere in the vast Portuguese-speaking world – a community of more than 230 million in a space that offers a wide array of investment opportunities across four continents – increasingly seek Portugal as their preferred seat of arbitration. A signatory to all relevant international conventions, Portugal has proven to be an ‘arbitration-friendly’ jurisdiction. This volume is the first and so far only book in English that provides a thorough, in-depth analysis of international arbitration law and practice in Portugal. Its contributing authors are among the most highly regarded legal names in the country, including scholars, arbitrators, and practitioners. The authors describe how international arbitration proceedings are conducted in Portugal, what cautions should be taken, and what procedural strategies may be suitable in particular cases. They provide insightful answers to questions such as the following: What matters can be submitted to arbitration under Portuguese law? What are the validity requirements for an arbitration agreement? How do the State courts interact with arbitration proceedings and what is the attitude of such courts toward international arbitration? What are the rules governing evidentiary matters in arbitration? How is an arbitration tribunal constituted? How are arbitrators appointed? How may they be challenged? How can an international arbitral award be recognized and enforced? How does the Portuguese legal system address the issue of damages and what specific damages are admitted? How are the costs of arbitration proceedings estimated and allocated? The book includes analyses of arbitration related to specific fields of the law, notably sports, administrative, tax, intellectual property rights (especially regarding reference and generic medicines), and corporate disputes. Each chapter provides, for the topics it addresses, an examination of the applicable laws, rules, arbitration practice, and views taken by arbitral tribunals and state courts as well as those of the most highly considered scholars. As a detailed examination of the legal framework and of all procedural steps of an arbitration in Portugal, from the drafting of an arbitration agreement to the enforcement of an award, this book constitutes an invaluable resource for parties involved in or considering an international arbitration in this country. The guidance that it seeks to provide in respect of any problem likely to arise in this context can be useful to arbitrators, judges, academics, and interested lawyers.

State Aid Law and Business Taxation

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Author :
Publisher : Springer
ISBN 13 : 3662530554
Total Pages : 283 pages
Book Rating : 4.6/5 (625 download)

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Book Synopsis State Aid Law and Business Taxation by : Isabelle Richelle

Download or read book State Aid Law and Business Taxation written by Isabelle Richelle and published by Springer. This book was released on 2016-10-18 with total page 283 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a compilation of contributions exploring the impact of the European Treaty provisions regarding state aid on Member States’ legislation and administrative practice in the area of business taxation. Starting from a detailed analysis of the European Courts’ jurisprudence on Art.107 TFEU the authors lay out fundamental issues – e.g. on legal concepts like “advantage”, “selectivity” and “discrimination” – and explore current problems – in particular policy and practice regarding “harmful” tax competition within the European Union. This includes the Member States’ Code of Conduct on business taxation, the limits to anti-avoidance legislation and the options for legislation on patent boxes. The European Commission’s recent findings on preferential “rulings” are discussed as well as the general relationship between international tax law, transfer pricing standards and the European prohibition on selective fiscal aids.

The Principle of Equality in European Taxation

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Publisher : Springer
ISBN 13 :
Total Pages : 324 pages
Book Rating : 4.3/5 (511 download)

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Book Synopsis The Principle of Equality in European Taxation by : Gerard Meussen

Download or read book The Principle of Equality in European Taxation written by Gerard Meussen and published by Springer. This book was released on 1999-10-12 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: Or her tax trial

Self-employment Tax

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Publisher :
ISBN 13 :
Total Pages : 12 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis Self-employment Tax by :

Download or read book Self-employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Foreign Ownership and Corporate Income Taxation

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Author :
Publisher :
ISBN 13 :
Total Pages : 64 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis Foreign Ownership and Corporate Income Taxation by : Harry Huizinga

Download or read book Foreign Ownership and Corporate Income Taxation written by Harry Huizinga and published by . This book was released on 2003 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recoge : 1. Introduction. - 2. Previous literature. - 3. The data. - 4. The estimation. - 5. Empirical results. - 6. Conclusions.