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Eleventh Meeting Of The Ad Hoc Group Of Experts On International Cooperation In Tax Matters
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Author :United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters Publisher : ISBN 13 : Total Pages :132 pages Book Rating :4.3/5 (91 download)
Book Synopsis International Cooperation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters
Download or read book International Cooperation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by . This book was released on 1998 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt: Report of the Ad Hoc Group of Experts on International Cooperation in Tax Matters on the work of its eighth meeting which was held from 15 to 19 December 1997 in Geneva, including selected papers presented at the meeting.
Book Synopsis Dispute Resolution Under Tax Treaties by : Zvi Daniel Altman
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Book Synopsis Mutual Assistance for the Recovery of Tax Claims by : Maria Amparo Grau Ruiz
Download or read book Mutual Assistance for the Recovery of Tax Claims written by Maria Amparo Grau Ruiz and published by Kluwer Law International B.V.. This book was released on 2003-01-14 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential powers and necessary limits of the mutual assistance function at the national administrative level. Includes recommendations for the strengthening and effectiveness of mutual assistance procedures, considers the growing role of multilateral treaties, and envisions the possibility of an international fiscal court.
Author :United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters Publisher : ISBN 13 : Total Pages :88 pages Book Rating :4.:/5 (334 download)
Book Synopsis International Co-operation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters
Download or read book International Co-operation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by . This book was released on 2005 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Special Features of the UN Model Convention by : Anna Binder
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 642 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.
Book Synopsis Report of the Committee on Conferences by : United Nations. General Assembly. Committee on Conferences
Download or read book Report of the Committee on Conferences written by United Nations. General Assembly. Committee on Conferences and published by . This book was released on 2007 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009 by :
Download or read book Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009 written by and published by . This book was released on 2009 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment by : United States. Congress. Joint Committee on Taxation
Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 2009 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print] by :
Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print] written by and published by . This book was released on 2009 with total page 258 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Yearbook of the United Nations, Volume 46 (1992) by : United Nations
Download or read book Yearbook of the United Nations, Volume 46 (1992) written by United Nations and published by Martinus Nijhoff Publishers. This book was released on 2023-08-28 with total page 1294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fully indexed, the 1992 edition of the Yearbook is the single most current, comprehensive and authoritative reference publication about the work of the United Nations, other international organizations and related bodies. The book is designed not just for use by diplomats, officials and scholars but also by other researchers, writers, journalists, teachers and students. The year 1992 was a remarkably eventful one for the United Nations and in the conduct of international relations. This volume of the Yearbook details the activities of the United Nations, its many organs, agencies and programmes, working together to rekindle a new form of multilateral cooperation for a better world. It records the diverse and globe-encompassing activities of the United Nations and its enduring efforts to deal with the world's pressing concerns, particularly matters of international peace and security, disarmament, human rights, the settlement of regional conflicts, economic and social development, the preservation of the environment, control of drugs and narcotic substance abuse, crime prevention, adequate shelter, youth and the ageing and humanitarian assistance for refugees as well as disaster relief. The Yearbooks for the years 1988, 1989 and 1990 are expected to be published within the next two years.
Book Synopsis Beneficial Ownership in International Taxation by : Kuźniacki, Błażej
Download or read book Beneficial Ownership in International Taxation written by Kuźniacki, Błażej and published by Edward Elgar Publishing. This book was released on 2022-08-12 with total page 385 pages. Available in PDF, EPUB and Kindle. Book excerpt: This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Błażej Kuźniacki presents a route towards an international autonomous meaning of beneficial ownership, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity.
Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal by :
Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal written by and published by . This book was released on 2009 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention by : David Orzechowski-Zölzer
Download or read book The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention written by David Orzechowski-Zölzer and published by Kluwer Law International B.V.. This book was released on 2024-05-21 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.
Download or read book United Nations Handbook written by and published by . This book was released on 2016 with total page 462 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Interface of International Trade Law and Taxation by : Jennifer E. Farrell
Download or read book The Interface of International Trade Law and Taxation written by Jennifer E. Farrell and published by IBFD. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores the ill-defined and oft-underestimated relationship between the World Trade Organization (WTO) and taxation. By adopting a two-pronged approach, the relationship is examined in terms of the extent to which the WTO legal framework exerts influence upon domestic tax law and international tax policy, and whether it is appropriate for the WTO to play a regulatory role in the field of taxation. The book begins with an examination of the historical development of international trade law and international tax law, and demonstrates that these two separate areas of law are closely linked in terms of their underlying principles and historical evolution. The work then goes on to offer a doctrinal analysis of the tax content found in the WTO legal texts and highlights ambiguities therein.
Author :Department of Public Information United Nations Publisher :Martinus Nijhoff Publishers ISBN 13 :9004636773 Total Pages :1140 pages Book Rating :4.0/5 (46 download)
Book Synopsis Yearbook of the United Nations 1991 by : Department of Public Information United Nations
Download or read book Yearbook of the United Nations 1991 written by Department of Public Information United Nations and published by Martinus Nijhoff Publishers. This book was released on 2023-12-28 with total page 1140 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fully indexed, the 1991 edition of the Yearbook is the single most current, comprehensive and authoritative reference publication about the work of the United Nations, other international organizations and related bodies. The book is designed not just for use by diplomats, officials and scholars but also by other researchers, writers, journalists, teachers and students. The year 1991 was a remarkably eventful one for the United Nations and in the conduct of international relations. This volume of the Yearbook details the activities of the United Nations, its many organs, agencies and programmes, working together to rekindle a new form of multilateral cooperation for a better world. It records the diverse and globe-encompassing activities of the United Nations and its enduring efforts to deal with the world's pressing concerns, particularly matters of international peace and security, disarmament, human rights, the settlement of regional conflicts, economic and social development, the preservation of the environment, control of drugs and narcotic substance abuse, crime prevention, adequate shelter, youth and the ageing and humanitarian assistance for refugees as well as disaster relief. The Yearbook of the United Nations is now up-to-date. The Yearbooks for the years 1988, 1989 and 1990 will be published simultaneously.
Book Synopsis Taxation of Derivatives and Cryptoassets by : Oktavia Weidmann
Download or read book Taxation of Derivatives and Cryptoassets written by Oktavia Weidmann and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 519 pages. Available in PDF, EPUB and Kindle. Book excerpt: Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.
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