Fiscalidad De Las Operaciones Vinculadas

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Resolving Transfer Pricing Disputes

Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)

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Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi

Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Combating Tax Avoidance in the EU

Author : José Manuel Almudí Cid
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501421
Total Pages : 880 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Combating Tax Avoidance in the EU by : José Manuel Almudí Cid

Download or read book Combating Tax Avoidance in the EU written by José Manuel Almudí Cid and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 880 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.

Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087221398
Total Pages : 1093 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto

Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.

The Future of the Profit Split Method

Author : Gabriella Cappelleri
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403524316
Total Pages : 341 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis The Future of the Profit Split Method by : Gabriella Cappelleri

Download or read book The Future of the Profit Split Method written by Gabriella Cappelleri and published by Kluwer Law International B.V.. This book was released on 2020-11-23 with total page 341 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.

Carbon Pricing, Growth and the Environment

Author : Lawrence A. Kreiser
Publisher : Edward Elgar Publishing
ISBN 13 : 1781952191
Total Pages : 305 pages
Book Rating : 4.7/5 (819 download)

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Book Synopsis Carbon Pricing, Growth and the Environment by : Lawrence A. Kreiser

Download or read book Carbon Pricing, Growth and the Environment written by Lawrence A. Kreiser and published by Edward Elgar Publishing. This book was released on 2012-01-01 with total page 305 pages. Available in PDF, EPUB and Kindle. Book excerpt: ïThe scope, depth and persistence with which this book explores carbon pricing is admirable, reflecting that despite political reluctance it is a topic in all parts of the world.Í _ Mikael Skou Andersen, Aarhus University, Denmark and European Environment Agency ïEnvironmental taxation and emissions trading continue to be high on the public policy agenda in many countries, and this is another welcome and very interesting volume in the Critical Issues in Environmental Taxation series that presents new ideas and evidence on these subjects from a wide range of countries and a variety of perspectives.Í _ Paul Ekins, University College London, UK This original and timely volume provides unique insights and analysis on the pressing question of how to achieve environmental sustainability while fostering economic growth. The emphasis of the book lies in finding critical solutions to global climate change including chapters on environmental fiscal reform and unemployment in Spain, EU structural and cohesion policy and sustainable development, ecological tax reform in Europe and Asia, AustraliaÍs carbon pricing mechanism, and many other timely topics. This insightful volume will appeal to policy makers in government as well as academics and students in environmental law, environmental economics and environmental sustainability.

The Future of Risk Management, Volume I

Author : Paola De Vincentiis
Publisher : Springer
ISBN 13 : 3030145484
Total Pages : 436 pages
Book Rating : 4.0/5 (31 download)

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Book Synopsis The Future of Risk Management, Volume I by : Paola De Vincentiis

Download or read book The Future of Risk Management, Volume I written by Paola De Vincentiis and published by Springer. This book was released on 2019-04-11 with total page 436 pages. Available in PDF, EPUB and Kindle. Book excerpt: With contributions presented during the Second International Risk Management Conference, this first volume addresses important areas of risk management from a variety of angles and perspectives. The book will cover three separate tracks, including: legal issues in risk management, risk management in the public sector and in healthcare, and environmental risk management, and will be of interest to academic researchers and students in risk management, banking, and finance.

ELLIS

Author :
Publisher :
ISBN 13 :
Total Pages : 382 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis ELLIS by :

Download or read book ELLIS written by and published by . This book was released on 1991 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fiscalidad de las operaciones vinculadas

Author : José Manuel Calderón Carrero
Publisher :
ISBN 13 : 9788482356402
Total Pages : 680 pages
Book Rating : 4.3/5 (564 download)

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Book Synopsis Fiscalidad de las operaciones vinculadas by : José Manuel Calderón Carrero

Download or read book Fiscalidad de las operaciones vinculadas written by José Manuel Calderón Carrero and published by . This book was released on 2009-03 with total page 680 pages. Available in PDF, EPUB and Kindle. Book excerpt: Análisis especializado y práctico de toda la problemática concerniente a la aplicación del régimen fiscal de las operaciones vinculadas, tanto nacional como internacional, con especial atención a las principales figuras que intervienen en la materia.

The Oxford Handbook of the Phoenician and Punic Mediterranean

Author : Carolina López-Ruiz
Publisher : Oxford University Press
ISBN 13 : 0197654428
Total Pages : 787 pages
Book Rating : 4.1/5 (976 download)

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Book Synopsis The Oxford Handbook of the Phoenician and Punic Mediterranean by : Carolina López-Ruiz

Download or read book The Oxford Handbook of the Phoenician and Punic Mediterranean written by Carolina López-Ruiz and published by Oxford University Press. This book was released on 2022 with total page 787 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Phoenicians created the Mediterranean world as we know it--yet they remain a poorly understood group. In this Handbook, the first of its kind in English, readers will find expert essays covering the history, culture, and areas of settlement throughout the Phoenician and Punic world.

Tartessos and the Phoenicians in Iberia

Author : Sebastián Celestino Pérez
Publisher : Oxford University Press
ISBN 13 : 0199672741
Total Pages : 389 pages
Book Rating : 4.1/5 (996 download)

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Book Synopsis Tartessos and the Phoenicians in Iberia by : Sebastián Celestino Pérez

Download or read book Tartessos and the Phoenicians in Iberia written by Sebastián Celestino Pérez and published by Oxford University Press. This book was released on 2016 with total page 389 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book in English about the earliest historical civilization in the western Mediterranean, known as "Tartessos". It combines the expertise of its two authors in archaeology, philology, and cultural history to present a comprehensive, coherent, theoretically up-to-date, and informative overview of the discovery, sources, and debates surrounding this puzzling culture of ancient Iberia and its complex hybrid identity vis-à-vis the western Phoenicians.

EC Tax Review

Author :
Publisher :
ISBN 13 :
Total Pages : 728 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis EC Tax Review by :

Download or read book EC Tax Review written by and published by . This book was released on 2002 with total page 728 pages. Available in PDF, EPUB and Kindle. Book excerpt:

When the Gods Were Born

Author : Carolina López-Ruiz
Publisher : Harvard University Press
ISBN 13 : 9780674049468
Total Pages : 324 pages
Book Rating : 4.0/5 (494 download)

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Book Synopsis When the Gods Were Born by : Carolina López-Ruiz

Download or read book When the Gods Were Born written by Carolina López-Ruiz and published by Harvard University Press. This book was released on 2010-06-15 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With admirable erudition, Lopez-Ruiz brings to life intimacies and exchanges between the ancient Greeks and their Northwest Semitic neighbors, portraying the ancient Mediterranean as a fluid, dynamic contact zone. She explains networks of circulation, shows creative uses of traditional material by peoples in motion, and radically transforms our understanding of ancient cosmogonies."---Page duBois, author of Out of Athens: The New Ancient Greeks --

Global Investment Competitiveness Report 2017/2018

Author : World Bank Group
Publisher : World Bank Publications
ISBN 13 : 1464811857
Total Pages : 281 pages
Book Rating : 4.4/5 (648 download)

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Book Synopsis Global Investment Competitiveness Report 2017/2018 by : World Bank Group

Download or read book Global Investment Competitiveness Report 2017/2018 written by World Bank Group and published by World Bank Publications. This book was released on 2017-10-25 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Global Investment Competitiveness report presents new insights and evidence on drivers of foreign direct investment (FDI) in developing countries, and FDI’s role in development. The report’s survey of 750 executives of multinational corporations finds that a business-friendly legal and regulatory environment is a key driver of investment decisions in developing countries, along with political stability, security, and macroeconomic conditions. The report’s topic-specific chapters explore the potential of FDI to create new growth opportunities for local firms, assess the power of tax holidays and other fiscal incentives to attract FDI, analyze characteristics of FDI originating in developing countries, and examine the experience of foreign investors in countries affected by conflict and fragility. Three key features of this Global Investment Competitiveness report distinguish it from other publications on FDI. First, its insights are based on a combination of first-hand perspectives of investors, extensive analysis of available data and evidence, and international good practices in investment policy design and implementation. Secondly, rather than exploring broad FDI trends, the report provides detailed and unique analysis of FDI depending on its motivation, sector, geographic origin and destination, and phase of investment. Thirdly, the report offers practical and actionable recommendations to policymakers in developing countries wishing to reform their business climates for increased investment competitiveness. As such, the report is meant to complement other knowledge products of the World Bank Group focused even more explicitly on country-level data, detailed reform diagnostics, and presentation of best practices. We are confident this report will bring value and fresh perspectives to a variety of audiences. To governments and policymakers, including investment promotion professionals, the report offers direct insights into the role of government policies and actions in investors’ decision-making. To foreign investors and site location consultants, the report provides information on FDI trends and drivers across sectors and geographies. For academic audiences, the new datasets on investment incentives and FDI motivations enables opportunities for additional research and analysis. Lastly, for development assistance providers and other stakeholders, the report highlights key approaches for maximizing FDI’s benefits for development.

The Skeleton

Author : Salvador Sanz
Publisher : Simon and Schuster
ISBN 13 : 1948761009
Total Pages : 152 pages
Book Rating : 4.9/5 (487 download)

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Book Synopsis The Skeleton by : Salvador Sanz

Download or read book The Skeleton written by Salvador Sanz and published by Simon and Schuster. This book was released on 2021-07-26 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt: For fans of dystopian action adventure, a small group of survivors make their way across a changed planet. The carnivore plague has engulfed the earth, any who eat meat are consumed by it, transforming into mindless savages who only want to eat more and more. Only the mysterious Skeleton and his gang of vicious vegetarians have survived and have a chance to find a cure... if they don't become dinner first.

The Latin American Ecocultural Reader

Author : Jennifer French
Publisher : Northwestern University Press
ISBN 13 : 0810142651
Total Pages : 602 pages
Book Rating : 4.8/5 (11 download)

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Book Synopsis The Latin American Ecocultural Reader by : Jennifer French

Download or read book The Latin American Ecocultural Reader written by Jennifer French and published by Northwestern University Press. This book was released on 2020-11-15 with total page 602 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Latin American Ecocultural Reader is a comprehensive anthology of literary and cultural texts about the natural world. The selections, drawn from throughout the Spanish-speaking countries and Brazil, span from the early colonial period to the present. Editors Jennifer French and Gisela Heffes present work by canonical figures, including José Martí, Bartolomé de las Casas, Rubén Darío, and Alfonsina Storni, in the context of our current state of environmental crisis, prompting new interpretations of their celebrated writings. They also present contemporary work that illuminates the marginalized environmental cultures of women, indigenous, and Afro-Latin American populations. Each selection is introduced with a short essay on the author and the salience of their work; the selections are arranged into eight parts, each of which begins with an introductory essay that speaks to the political, economic, and environmental history of the time and provides interpretative cues for the selections that follow. The editors also include a general introduction with a concise overview of the field of ecocriticism as it has developed since the 1990s. They argue that various strands of environmental thought—recognizable today as extractivism, eco-feminism, Amerindian ontologies, and so forth—can be traced back through the centuries to the earliest colonial period, when Europeans first described the Americas as an edenic “New World” and appropriated the bodies of enslaved Indians and Africans to exploit its natural bounty.

Social and Solidarity Economy

Author : Peter Utting
Publisher : Zed Books Ltd.
ISBN 13 : 178360347X
Total Pages : 376 pages
Book Rating : 4.7/5 (836 download)

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Book Synopsis Social and Solidarity Economy by : Peter Utting

Download or read book Social and Solidarity Economy written by Peter Utting and published by Zed Books Ltd.. This book was released on 2015-04-09 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: As economic crises, growing inequality and climate change prompt a global debate on the meaning and trajectory of development, increasing attention is focusing on 'social and solidarity economy' as a distinctive approach to sustainable and rights-based development. While we are beginning to understand what social and solidarity economy is, what it promises and how it differs from 'business as usual', we know far less about whether it can really move beyond its fringe status in many countries and regions. Under what conditions can social and solidarity economy scale up and scale out - that is, expand in terms of the growth of social and solidarity economy organizations and enterprises, or spread horizontally within given territories? Bringing together leading researchers, blending theoretical and empirical analysis, and drawing on experiences and case studies from multiple countries and regions, this volume addresses these questions. In so doing, it aims to inform a broad constituency of development actors, including scholars, practitioners, activists and policy makers.

La Panadería, 1994-2002

Author : Alex Dorfsman
Publisher : Turner
ISBN 13 :
Total Pages : 328 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis La Panadería, 1994-2002 by : Alex Dorfsman

Download or read book La Panadería, 1994-2002 written by Alex Dorfsman and published by Turner. This book was released on 2005 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: Throughout eight years of existence, La Panadería served Mexico City as a vibrant non-profit space for exhibitions, residencies, and cultural events involving local and international artists. This retrospective catalogue exists as a collective testimony on the artistic productions and exhibitions that resulted from the space, which was founded in 1994 in a former bakery by local artists Yoshua Okon and Miguel Calderón. La Panadería emphasized, by way of its inherent nature, the integration of eclectic marginal practices. Young artists were invited to exhibit video, photography, installation and performance-based works, but the space was also characterized by parties and concerts, reflecting a lifestyle and a social dynamic that opposed a rigid set of paradigms which dictated how art should be. La Panadería: 1994-2002 is a visual and theoretical digest representative of the national and international art scene, presenting a selection of 60 exhibitions by foreign and Mexican contemporary artists via photographic documentation, a brief descriptive text, and ephemera such as invitations. Six critical texts consider the relevance of the space, while anecdotes from artists and the visiting public pay testimony to it. Dozens of artists are represented here, including Carlos Amorales, Chris Johanson, Emily Jacir, Francis Alÿs, Gelatin, Kirsten Stoltmann, Las ultrasónicas, Luis Felipe Ortega, Miguel Calderón, Minerva Cuevas, Semefo, Shepard Fairey and Uri Tzaig. The book is accompanied by a CD with music by Silverio.