Evolution Of Apa Regime

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Evolution of APA Regime

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535520
Total Pages : 252 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Evolution of APA Regime by : Kuldeep Sharma

Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.

GloBE Rules Made Easy

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403511664
Total Pages : 340 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis GloBE Rules Made Easy by : Kuldeep Sharma

Download or read book GloBE Rules Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2022-12-09 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.

The Trouble with Tradition

Author : Simon Young
Publisher : Federation Press
ISBN 13 : 9781862876477
Total Pages : 534 pages
Book Rating : 4.8/5 (764 download)

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Book Synopsis The Trouble with Tradition by : Simon Young

Download or read book The Trouble with Tradition written by Simon Young and published by Federation Press. This book was released on 2008 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a broad and detailed examination of the native title jurisprudence in the US, Canada, New Zealand and Australia, with a specific focus on the handling of Indigenous community changes in each country's case law.

Sanctions Regimes of Multilateral Development Banks

Author : Jelena Madir
Publisher : BRILL
ISBN 13 : 9004414126
Total Pages : 280 pages
Book Rating : 4.0/5 (44 download)

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Book Synopsis Sanctions Regimes of Multilateral Development Banks by : Jelena Madir

Download or read book Sanctions Regimes of Multilateral Development Banks written by Jelena Madir and published by BRILL. This book was released on 2020-11-30 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Sanctions Regimes of Multilateral Development Banks: What Process is Due, Jelena Madir examines the type of due process rights and the level of transparency that should characterise sanctions regimes of multilateral development banks.

Environmental Justice and Sustainable Development

Author : Götz Ferdinand Kaufmann
Publisher : Götz Kaufmann
ISBN 13 :
Total Pages : 424 pages
Book Rating : 4./5 ( download)

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Book Synopsis Environmental Justice and Sustainable Development by : Götz Ferdinand Kaufmann

Download or read book Environmental Justice and Sustainable Development written by Götz Ferdinand Kaufmann and published by Götz Kaufmann. This book was released on 2012 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Progressivism

Author : Bradley C. S. Watson
Publisher : University of Notre Dame Pess
ISBN 13 : 0268106991
Total Pages : 325 pages
Book Rating : 4.2/5 (681 download)

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Book Synopsis Progressivism by : Bradley C. S. Watson

Download or read book Progressivism written by Bradley C. S. Watson and published by University of Notre Dame Pess. This book was released on 2020-02-28 with total page 325 pages. Available in PDF, EPUB and Kindle. Book excerpt: At its core this book is intellectual history, tracing the work of progressive historians as they in turn wrote the history of progressivism. In Progressivism: The Strange History of a Radical Idea, Bradley C. S. Watson presents an intellectual history of American progressivism as a philosophical-political phenomenon, focusing on how and with what consequences the academic discipline of history came to accept and propagate it. This book offers a meticulously detailed historiography and critique of the insularity and biases of academic culture. It shows how the first scholarly interpreters of progressivism were, in large measure, also its intellectual architects, and later interpreters were in deep sympathy with their premises and conclusions. Too many scholarly treatments of the progressive synthesis were products of it, or at least were insufficiently mindful of two central facts: the hostility of progressive theory to the Founders’ Constitution and the tension between progressive theory and the realm of the private, including even conscience itself. The constitutional and religious dimensions of progressive thought—and, in particular, the relationship between the two—remained hidden for much of the twentieth century. This pathbreaking volume reveals how and why this scholarly obfuscation occurred. The book will interest students and scholars of American political thought, the Progressive Era, and historiography, and it will be a useful reference work for anyone in history, law, and political science.

The Spatial Factor In African History

Author : Allen M. Howard
Publisher : BRILL
ISBN 13 : 9004139133
Total Pages : 385 pages
Book Rating : 4.0/5 (41 download)

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Book Synopsis The Spatial Factor In African History by : Allen M. Howard

Download or read book The Spatial Factor In African History written by Allen M. Howard and published by BRILL. This book was released on 2005 with total page 385 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this collection authors apply spatial analysis to case studies of social, economic, and political dynamics in West, Central, and East Africa during the nineteenth and twentieth century. Also included is a lengthy essay re-interpreting tropical Africa, 1800-1930, using spatial theory.

Lessons from Nationalist Struggle

Author : Jose Dalisay Jr.
Publisher : Anvil Publishing, Inc.
ISBN 13 : 9712733157
Total Pages : 101 pages
Book Rating : 4.7/5 (127 download)

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Book Synopsis Lessons from Nationalist Struggle by : Jose Dalisay Jr.

Download or read book Lessons from Nationalist Struggle written by Jose Dalisay Jr. and published by Anvil Publishing, Inc.. This book was released on 2017-11-15 with total page 101 pages. Available in PDF, EPUB and Kindle. Book excerpt: An Unknown Chapter in Philippine History Emmanuel Quiason Yap possessed a unique perspective on world affairs. This was largely a product of his upbringing and life experience, which underpinned his great love of country. Through his life, we see a clear view of the road not taken. This book portrays one of the most significant and turbulent chapters in Philippine history in this context. The period from the late 1950s to the early 1970s witnessed a resurgence of the nationalist movement, the election of Ferdinand Marcos as president, the establishment of the Communist Party of the Philippines, the First Quarter Storm, the bombing of Plaza Miranda, and the declaration of martial law. Manoling Yap cast a different light on these events, including the roles of Marcos, and Ninoy and Cory Aquino. Inevitably, many disagreed with his analysis and some dismissed him as a Communist. Ironically, it was during this period that his career reached both its zenith and nadir. Because of illness, he was unable to write his autobiography as he had always intended. But his analysis and interpretation of important events present an alternative viewpoint that must be known. This is Manoling Yap’s story

The Evolution of Social Innovation

Author : Frances Westley
Publisher : Edward Elgar Publishing
ISBN 13 : 1786431157
Total Pages : 288 pages
Book Rating : 4.7/5 (864 download)

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Book Synopsis The Evolution of Social Innovation by : Frances Westley

Download or read book The Evolution of Social Innovation written by Frances Westley and published by Edward Elgar Publishing. This book was released on 2017-12-29 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a time where governments and civil society organizations are putting ever-greater stock in social innovation as a route to transformation, understanding what characterizes social innovation with transformative potential is important. Exciting and promising ideas seem to die out as often as they take flight, and market mechanisms, which go a long way towards contributing to successful technical innovations, play an insignificant role in social innovations. The cases in this book explore the evolution of successful social innovation through time, from the ideas which catalysed social and system entrepreneurs to create new processes, platforms, projects and programs to fundamental social shifts in culture, economics, laws and policies which occurred as a result. In doing so, the authors shed light on how to recognize transformative potential in the early stage innovations we see today.

Advance Pricing Agreements

Author : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041140727
Total Pages : 408 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Advance Pricing Agreements by : Michelle Markham

Download or read book Advance Pricing Agreements written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2012-06-28 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ‘tax risk appetite’ on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) – arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.

Four Crises of American Democracy

Author : Alasdair Roberts
Publisher : Oxford University Press
ISBN 13 : 0190459913
Total Pages : 240 pages
Book Rating : 4.1/5 (94 download)

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Book Synopsis Four Crises of American Democracy by : Alasdair Roberts

Download or read book Four Crises of American Democracy written by Alasdair Roberts and published by Oxford University Press. This book was released on 2016-12-13 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the last decade, observers of Western governments have become increasingly concerned about an apparent crisis of democracy. They argue that endemic corruption, inadequate services, and increasing voter disaffection have produced a dire result: a global resurgence of authoritarianism. The political climate surrounding the 2016 presidential election in the United States has only reinforced the perception of democratic crisis. In Four Crises of American Democracy, Alasdair Roberts locates the U.S.'s recent bout of democratic malaise in a larger context, arguing that it is the latest in a series of very different crises that have plagued America throughout the entire post-Civil War era. He focuses on four crises, describing the features of each and outlining solutions the government adopted in response. The first crisis-the "crisis of representation"-occurred in the late nineteenth and early twentieth centuries, and was dominated by fears of plutocracy and debates about the rights of African Americans, women, and immigrants. The "crisis of mastery" spanned the years 1917-1948, and focused on building administrative capabilities so that government could better manage both an increasingly complex economy and volatile international system. The "crisis of discipline," beginning in the 1970s, was triggered by the perception that voters and special interests were overloading governments with unreasonable demands, and the response was to limit government's reach. The current crisis, what Roberts calls the "crisis of anticipation," is ongoing. Roberts pronounces it a future-oriented crisis, preoccupied with the capacity of democratic systems to deal with long-term problems such the rise of China and climate change. Roberts suggests that democratic solutions to this present crisis will win out over more authoritarian ones, as occurred in previous crises. Features like societal openness and pragmatism give the democratic model a distinct advantage. A powerful account of how successive crises have shaped American democracy, this is essential reading for anyone interested in the forces driving the current democratic malaise both in the U.S. and around the world.

Taxation in Ghana: a Fiscal Policy Tool for Development

Author : Dr. George Appiah-Sokye
Publisher : AuthorHouse
ISBN 13 : 1665528311
Total Pages : 860 pages
Book Rating : 4.6/5 (655 download)

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Book Synopsis Taxation in Ghana: a Fiscal Policy Tool for Development by : Dr. George Appiah-Sokye

Download or read book Taxation in Ghana: a Fiscal Policy Tool for Development written by Dr. George Appiah-Sokye and published by AuthorHouse. This book was released on 2021-07-01 with total page 860 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first edition of this book-Taxation in Ghana: A Fiscal Policy Tool for Development- is the product of considerable tax research from 1943 to 2018, spanning a period of 75 years and grounded in knowledge and concepts; as well as, applications through an extended period of tax practice, teaching and learning; combined with international exposure. A lot of insights have been illuminated based on lessons learned and drawn from other countries, including the United States of America to enrich the contents. Against the backdrop of the dynamic nature of taxation and fiscal policy. Most of the existing taxation books in Ghana focused on tax practice. So, the purpose of this book is to bridge the taxation scholarship gap. In addition to traditionally-treated topics in most taxation books in Ghana, the novelty in this book is the inclusion of important topics on tax planning, tax reforms, and tax administration, and many more. As a result, specific recommendations have been proffered for the consideration of policy makers in developing countries. References and Acts of Parliament; supported by appendices have been provided for further studies on the subject. A true story of the first major oil discovery in Ghana by Mr. George Yaw Owusu with M. Rutledge McCall published 2017 in the United States of America: In Pursuit of JUBILEE was used to enrich the discussion on petroleum (Oil and Gas) in Chapter 48 of this textbook. Additionally, Apostle Professor Opoku Onyinah of the Church of Pentecost has been presented for his phenomenal transformational leadership in Africa in Chapter 66. The book has been designed for: (1) Individual study, (2) Group study, (3) Lecture material, (4) Policy Manual, and (5) library or reference.

Guide to International Transfer Pricing

Author : Dr A. Michael Heimert
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501715
Total Pages : 1290 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Guide to International Transfer Pricing by : Dr A. Michael Heimert

Download or read book Guide to International Transfer Pricing written by Dr A. Michael Heimert and published by Kluwer Law International B.V.. This book was released on 2018-10-26 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt: The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

International Taxation Handbook

Author : Colin Read
Publisher : Elsevier
ISBN 13 : 0750683716
Total Pages : 391 pages
Book Rating : 4.7/5 (56 download)

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Book Synopsis International Taxation Handbook by : Colin Read

Download or read book International Taxation Handbook written by Colin Read and published by Elsevier. This book was released on 2007-04-13 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.

Feeling Asian American

Author : Wen Liu
Publisher : University of Illinois Press
ISBN 13 : 0252056671
Total Pages : 254 pages
Book Rating : 4.2/5 (52 download)

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Book Synopsis Feeling Asian American by : Wen Liu

Download or read book Feeling Asian American written by Wen Liu and published by University of Illinois Press. This book was released on 2024-05-07 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Asian Americans have become the love-hate subject of the American psyche: at times celebrated as the model minority, at other times hated as foreigners. Wen Liu examines contemporary Asian American identity formation while placing it within a historical and ongoing narrative of racial injury. The flexible racial status of Asian Americans oscillates between oppression by the white majority and offers to assimilate into its ranks. Identity emerges from the tensions produced between those two poles. Liu dismisses the idea of Asian Americans as a coherent racial population. Instead, she examines them as a raced, gendered, classed, and sexualized group producing varying physical and imaginary boundaries of nation, geography, and citizenship. Her analysis reveals repeated norms and acts that capture Asian Americanness as part of a racial imagination that buttresses capitalism, white supremacy, neoliberalism, and the US empire. An innovative challenge to persistent myths, Feeling Asian American ranges from the wartime origins of Asian American psychology to anti-Asian attacks to present Asian Americanness as a complex political assemblage.

Comparative Law Yearbook of International Business Volume 43

Author : Christian Campbell
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535318
Total Pages : 195 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Comparative Law Yearbook of International Business Volume 43 by : Christian Campbell

Download or read book Comparative Law Yearbook of International Business Volume 43 written by Christian Campbell and published by Kluwer Law International B.V.. This book was released on 2021-11-11 with total page 195 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.

Environment and Sustainable Development

Author : Manish K. Verma
Publisher : Taylor & Francis
ISBN 13 : 1000486397
Total Pages : 324 pages
Book Rating : 4.0/5 (4 download)

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Book Synopsis Environment and Sustainable Development by : Manish K. Verma

Download or read book Environment and Sustainable Development written by Manish K. Verma and published by Taylor & Francis. This book was released on 2021-11-29 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume provides a comprehensive account of the linkages between environment and sustainable development in society from an interdisciplinary perspective. With its case studies from across the world, including countries such as India, Australia, South Africa, Sri Lanka, the United States, Croatia, Italy, Brazil, Japan, and Kenya, it explores critical environmental issues concerning energy justice, queer ecology, mountain cultures, incarceration, energy strategies, mining tourism, pollution control mechanisms, social impacts of oil and gas production, contract farming, gender mainstreaming, climate change, and droughts and adaptation strategies along with literacy, leisure, well-being, development, sexuality, sustainability and environmental education. The book examines several dimensions within global environment of the adverse impact of developmental activities, discusses sustainable development activities undertaken in contemporary times, and underscores the importance of a just, people-centric policy framework in promoting sustainable development. Lucid and topical, this book will be useful to scholars and researchers of environmental studies, development studies, sustainable development, political studies, sociology, and political economy. It will also interest policymakers, development practitioners, NGOs and think tanks working on environment and sustainable development, climate issues and SDGs.