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Current Developments In Taxation Of International Business And Banking Transactions
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Book Synopsis Current Developments in Taxation of International Business and Banking Transactions by : International Tax Institute
Download or read book Current Developments in Taxation of International Business and Banking Transactions written by International Tax Institute and published by . This book was released on 1974 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: Selected papers and outlines of panelists at 1974 Public Technical Meetings in New York and Los Angelos of International Tax Institute, Inc.
Book Synopsis International Taxation of Banking by : John Abrahamson
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Book Synopsis Selected Papers and Outlines of Panelists at 1974 Public Technical Meetings ... by : International Tax Institute
Download or read book Selected Papers and Outlines of Panelists at 1974 Public Technical Meetings ... written by International Tax Institute and published by . This book was released on 1975 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of International Business Transactions by : Felix I. Lessambo
Download or read book Taxation of International Business Transactions written by Felix I. Lessambo and published by iUniverse. This book was released on 2009 with total page 363 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With the increase in global trade now and in the future and the growth of multinational companies, an understanding of international tax law is imperative. In Taxation of International Business Transactions, author Dr. Felix Lessambo provides an overview of the sometimes challenging international tax law. Taxation of International Business Transactions provides sound understanding of foreign tax regimes and more. It is geared for those who want to mitigate, increase, and avoid tax audits in the areas of thin-capitalization, employee-secondment, transfer pricing, and limitations-on-benefits (LOB). Lessambo has tracked the ongoing issues of the most relevant aspects of international taxations and delivers suggestions in this edition. Lessambo, an international tax scholar and practitioner recognized for his keen analyses, provides firsthand expertise to help multinationals and international business managers to pursue business initiatives without the fear of unintended tax consequences. Taxation of International Business Transactions is an indispensable guide for tax and financial directors and those dealing with tax at a worldwide level."--Publisher's website.
Book Synopsis Transfer Pricing and Financial Transactions by : Michael Lang
Download or read book Transfer Pricing and Financial Transactions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2022-03-16 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries. With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.
Book Synopsis Studies in International Taxation by : Alberto Giovannini
Download or read book Studies in International Taxation written by Alberto Giovannini and published by University of Chicago Press. This book was released on 1993-09-15 with total page 348 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents research on how taxes affect the investment and financing decisions of multinationals. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies.
Book Synopsis Understanding International Business and Financial Transactions by : Jerold A. Friedland
Download or read book Understanding International Business and Financial Transactions written by Jerold A. Friedland and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This concise, readable Understanding treatise provides an overview of International Business and Financial Transactions. Based on the author's many years of legal experience, teaching, and studying in countries throughout the world, it provides both law students and practitioners with a practical summary of relevant topics. This edition also covers a wide range of topics relating to money, currency and finance in International Trade, The Rules of International Trade, United States Trade Laws, international sales, operating in foreign markets and taxation of international transactions. Understanding International Business and Financial Transactions also addresses recent developments in international business and finance particularly since the global financial crisis reached its full force in 2008. About the Author Professor Friedland specializes in the areas of international business and taxation, and he is a well-known expert on partnerships, limited liability companies, and international joint ventures. He has served as director of DePaul's Graduate Tax Law Program, worked for the chief counsel of the Internal Revenue Service, and practiced law in Denver.
Book Synopsis Transfer Pricing Developments Around the World 2020 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis Selected Papers and Outlines of Panelists at 1974 Public Technical Meetings in New York and Los Angeles of International Tax Institute, Inc. (formerly, Institute on U. S. Taxation of Foreign Incomce, Inc.) on Current Developments in Taxation of International Business and Banking Transactions by : International Tax Institute
Download or read book Selected Papers and Outlines of Panelists at 1974 Public Technical Meetings in New York and Los Angeles of International Tax Institute, Inc. (formerly, Institute on U. S. Taxation of Foreign Incomce, Inc.) on Current Developments in Taxation of International Business and Banking Transactions written by International Tax Institute and published by . This book was released on 1974 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Financial sector taxation by : [Anonymus AC08741538]
Download or read book Financial sector taxation written by [Anonymus AC08741538] and published by . This book was released on 2010 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The global economic and financial crisis has created important needs for fiscal consolidation. This document analyses potential instruments to raise additional tax revenues from the financial sector. The first section reviews the current policy objectives related to the taxation of the financial sector. The second section sheds some light on the current tax treatment of the financial sector. The third section discusses potential tax instruments to reach the goals. The fourth and fifth section respectively assess the advantages and drawbacks of a Financial Transaction Tax and a Financial Activities Tax."--Editor.
Book Synopsis Latest Developments in U.S. Taxation of International Business by : International Tax Institute
Download or read book Latest Developments in U.S. Taxation of International Business written by International Tax Institute and published by . This book was released on 1978 with total page 313 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing Developments Around the World 2019 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2019 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-08-09 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based papers prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on Transfer Pricing and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. The intense work of international organizations such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis International Tax Primer by : Brian J. Arnold
Download or read book International Tax Primer written by Brian J. Arnold and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 421 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition. Unquestionably, the most important development in international tax since the publication of the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition explores in detail both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. Also new to the fifth edition are sections dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: taxation of residents on foreign income and nonresidents on domestic income; mechanisms used to mitigate the risks to taxpayers of international double taxation; transfer pricing rules to prevent the avoidance of tax by multinational corporations; anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Book Synopsis International Applications of U.S. Income Tax Law by : Ernest R. Larkins
Download or read book International Applications of U.S. Income Tax Law written by Ernest R. Larkins and published by John Wiley & Sons. This book was released on 2003-11-20 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
Book Synopsis International Business Transactions and Taxation by : Manuel C. Solbach
Download or read book International Business Transactions and Taxation written by Manuel C. Solbach and published by Springer Nature. This book was released on 2023-11-12 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent developments in the taxation of international enterprises are driven by the Organisation for Economic Co-operation and Development (OECD) of the Base Erosion and Profit Shifting (BEPS) initiative and have contributed to increase attention in practice, especially of large enterprises, resulting in different routes of action. This book provides a comprehensive overview of international business transactions at the customer interface with a focus on the specific role and tasks of the functions within a company. Three basic transactional models are introduced and analyzed, particularly to what extent they induce an international tax risk to the enterprise, in order to explore meaningful choices for action. The book inspires experienced practitioners as well as young professionals with or without formal business education to think beyond the context of their own experience and to define, implement and monitor tax-compliant transactional processes in their respective business. Individuals in companies are sensitized for compliance to these business processes resulting in a reduction of a hidden or frequently neglected, but significant tax risk. This book helps executives and managers create a shared understanding on international business transactions and facilitate detailed cross-functional discussions.
Book Synopsis Taxing International Business by : Australia. Treasury
Download or read book Taxing International Business written by Australia. Treasury and published by OECD Publishing. This book was released on 1997 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt: Contributions by various authors to the APEC-OECD Symposium on International Business Taxation, held on 30 October - 1 November 1996, hosted by the Australian Treasury and the Australian Taxation Office. The meeting examined the tax policy and tax administration issues which arise in taxing international businesses. Discussions focused on the challenges facing tax administration over the next decade, problems encountered by APEC economies in applying the OECD Transfer Pricing Guidelines and on how to minimise conflicts in this area both between Tax Administrations and taxpayers.
Book Synopsis The Economic Security of Business Transactions by : Professor Konrad Raczkowski
Download or read book The Economic Security of Business Transactions written by Professor Konrad Raczkowski and published by Chartridge Books Oxford. This book was released on 2013-10-15 with total page 460 pages. Available in PDF, EPUB and Kindle. Book excerpt: Summary ‘The Economic Security of Business Transactions’ covers such aspects as: management in the economic system; commercial risk in domestic and international transactions; an assessment of partners; unofficial economy and the state budget; economic security business; the role and importance of law in business. The book looks at the threats and risks arising from international trade and operating leading businesses, plus the role of the State. It examines the required new forms, methods and approaches for management. This has significant implications for the businesses concerned and the State’s role. ‘The Economic Security of Business Transactions’ includes coverage of internal company factors, tax evasion and tax avoidance; the book also looks at the level of involvement of the State (especially the EU’s Common Market). This leads to abuses and distortions in the area of the competitiveness of enterprises and countries’ competitiveness; it also changes the perception of contemporary economic security. This book is an attempt to point to the example of single countries, the European Community, and on a global scale – what is the efficiency of national economic systems and how the associated risks impact upon economic trade disorders. Key Features Contains contributions from some of the world’s leading researchers. Has an interdisciplinary character – based on economics, management and law. Shows and defines real threats and risks which occur in economic trade. The Authors Konrad Raczkowski is Professor of Management, who specializes in the unofficial economy, public finances and management in the economic system. He is a Director of Economic Institute in University of Social Sciences in Warsaw; he was Head of the Department of the Economic Security Management. Between 2003 and 2013 he worked in the finance department. He was also the advisor and consultant to governmental institutions, entrepreneurs and the European Anti-Fraud Office in Brussels (OLAF). He has qualifications as an internal auditor of integrated management systems. Professor Raczkowski is a member of British Academy of Management and since 2008 he has been an associate of the Institute for Security and Development Policy in Stockholm. Friedrich Schneider is Professor of Economics at the Department of Economics at the Johannes Kepler University of Linz in Austria. He is recognized as a leading authority in the field of studies on the shadow world economy. He has conducted research and lectures, among institutions such as the Universities of Yale, Princeton, Virginia, Stockholm, Zurich, Carnegie Mellon and Aarhus. In the years 1997-1999 he was the President of the Austrian Economic Association and in 2005-2008 the President of the German Economic Association. He has advised many governments, entrepreneurs and the European Commission. He is the author or co-author of hundreds of publications, including 62 books published in many languages. Professor Schneider’s research interests focus on the theory of economic policy, finance and the analysis of economic consequences of government intervention. Readership Scientists and researchers of national economy and unofficial economy; people experienced in the management (public and business); entrepreneurs; and students Contents PART I. SHADOW ECONOMY AND TAX EVASION CHAPTER 1 Size and development of the shadow economy and of tax evasion within Poland and of its neighbouring countries from 2003 to 2013: some new facts (Friedrich Schneider and Konrad Raczkowski) CHAPTER 2 How to curtail Poland’s shadow economy: the viewpoints of business and tax authorities (Bogdan Mróz and Mariusz Sokolek) CHAPTER 3 Shadow banking versus the shadow economy in Poland (Jan K. Solarz) CHAPTER 4 Why VAT carousel crime schemes are almost impossible to prosecute in Poland? (Czeslaw J_drzejek, Jacek Wi_ckowski, Maciej Nowak and Jaroslaw Bak) CHAPTER 5 The latest changes in the French tax evasion policy and its influence on economic and financial security (Urszula Zawadzka-Pak) PART II. ECONOMY AND BUSINESS TRANSACTIONS CHAPTER 6 The idea of homo oeconomicus and the role of culture in the economy (Marian Noga) CHAPTER 7 The implications of tax competition and "race to the bottom" for economic growth (Jolanta Szolno-Koguc and Malgorzata Twarowska) CHAPTER 8 Correct planning of budget revenue as an essential condition for secure business transactions (Eugeniusz Ruskowski) CHAPTER 9 The effects of public transfers on an economic system (Marta Postula) CHAPTER 10 The role of marketing information in the assessment of a contractor’s credibility in business negotiations (Bogdan Gregor and Magdalena Kalinska-Kula) CHAPTER 11 Implementation of the business counterintelligence branch in enterprise structure (Miroslaw Kwieci_ski and Krzysztof Passella) CHAPTER 12 Systematization of risk in internal and international markets (Katarzyna Zukrowska) CHAPTER 13 The role of the supreme audit office in tackling corruption and other types of organisational pathologies (Zbyslaw Dobrowolski) CHAPTER 14 Analysis of state bank guarantees offered to enterprises by national bank holdings and system solutions in selected countries (Dorota Ostrowska) CHAPTER 15 Common banking supervision within the financial safety net (Beata Domanska-Szaruga) CHAPTER 16 Crisis management in the global economy (Robert Dygas) PART III. MANAGEMENT AND ECONOMIC SECURITY CHAPTER 17 Business Process Management as a way to achieve national economic security (Piotr Senkus) CHAPTER 18 Collaborative networks as a basis for internal economic security in sustainable local governance. The case of Poland (Barbara Kozuch and Katarzyna Sienkiewicz-Malyjurek) CHAPTER 19 Changes in European foreign trade in the context of economic security (Agnieszka Glodowska) CHAPTER 20 The impact of non-military threats to economic security (Andrzej Limanski, Zbigniew Grzywna and Ireneusz Drabik)
