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International Company Taxation In The Era Of Information And Communication Technologies
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Book Synopsis International Company Taxation in the Era of Information and Communication Technologies by : Anne Schäfer
Download or read book International Company Taxation in the Era of Information and Communication Technologies written by Anne Schäfer and published by Springer Science & Business Media. This book was released on 2007-12-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.
Book Synopsis Value Added Tax and Direct Taxation by : Michael Lang
Download or read book Value Added Tax and Direct Taxation written by Michael Lang and published by IBFD. This book was released on 2009 with total page 1341 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.
Book Synopsis Taxation in a Global Digital Economy by : Ina Kerschner
Download or read book Taxation in a Global Digital Economy written by Ina Kerschner and published by Linde Verlag GmbH. This book was released on 2017-10-04 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Book Synopsis The Taxation of Permanent Establishments by : Sven Hentschel
Download or read book The Taxation of Permanent Establishments written by Sven Hentschel and published by Springer Nature. This book was released on 2021-06-26 with total page 521 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Book Synopsis EU Freedoms, Non-EU Countries and Company Taxation by : D.S. Smit
Download or read book EU Freedoms, Non-EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Book Synopsis Tec(h)tonic Shifts: Taxing the “Digital Economy” by : Aqib Aslam
Download or read book Tec(h)tonic Shifts: Taxing the “Digital Economy” written by Aqib Aslam and published by International Monetary Fund. This book was released on 2020-05-29 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.
Book Synopsis Tax Reform in the 21st Century by : John G. Head
Download or read book Tax Reform in the 21st Century written by John G. Head and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 578 pages. Available in PDF, EPUB and Kindle. Book excerpt: No government can be sustained without the ability to tax its citizens. The question then arises how can a nation do so in a way that's fair and equitable to taxpayers while simultaneously promoting economic growth and providing the state with the funds it needs to adequately address the needs of its citizens? This insightful work, featuring contributions from a stellar array of international tax experts and economists, addresses the crucial, relevant issues which developed countries will confront in the early decades of the 21st century: The pursuit of tax reform. Personal tax base: income or consumption? Tax rate scale: equity and efficiency aspects. Business tax reform: structural and design issues. Interjurisdictional issues. Controlling tax avoidance.
Book Synopsis A Common Tax Base for Multinational Enterprises in the European Union by : Carsten Wendt
Download or read book A Common Tax Base for Multinational Enterprises in the European Union written by Carsten Wendt and published by Springer Science & Business Media. This book was released on 2009-04-16 with total page 231 pages. Available in PDF, EPUB and Kindle. Book excerpt: Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.
Book Synopsis Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context by : Sven-Eric Bärsch
Download or read book Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context written by Sven-Eric Bärsch and published by Springer Science & Business Media. This book was released on 2012-12-13 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.
Book Synopsis Electronic Consumer Contracts in the Conflict of Laws by : Zheng Sophia Tang
Download or read book Electronic Consumer Contracts in the Conflict of Laws written by Zheng Sophia Tang and published by Bloomsbury Publishing. This book was released on 2015-10-22 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: The second edition of this highly recommended work addresses the interaction between conflict of laws, dispute resolution, electronic commerce and consumer contracts. In addition it identifies specific difficulties that conflicts lawyers and consumer lawyers encounter in electronic commerce and proposes original approaches to balance the conflict of interest between consumers' access to justice and business efficiency. The European Union has played a leading role in this area of law and its initiatives are fully explored. It pays particular attention to the most recent development in collective redress and alternative/online dispute resolution. By adopting multiple research methods, including a comparative study of the EU and US approach; historical analysis of protective conflict of laws; doctrinal analysis of legal provisions and economic analysis of law, it provides the most comprehensive examination of frameworks in cross-border consumer contracts.
Author :United Nations Conference on Trade and Development Publisher :United Nations Publications ISBN 13 : Total Pages :68 pages Book Rating :4.3/5 (91 download)
Book Synopsis Taxation and Technology Transfer by : United Nations Conference on Trade and Development
Download or read book Taxation and Technology Transfer written by United Nations Conference on Trade and Development and published by United Nations Publications. This book was released on 2005 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The report gives an overview of the impact of taxation in developed and developing countries on the transfer of technology and seeks to shed light on the formulation of tax policies that could facilitate technology transfer"--Page iii.
Book Synopsis Taxing Telecommunications in Developing Countries by : Ms.Thornton Matheson
Download or read book Taxing Telecommunications in Developing Countries written by Ms.Thornton Matheson and published by International Monetary Fund. This book was released on 2017-11-15 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: Developing countries apply numerous sector-specific taxes to telecommunications, whose buoyant revenues and formal enterprises provide a convenient “tax handle”. This paper explores whether there is an economic rationale for sector-specific taxes on telecommunications and, if so, what form they should take to balance the competing goals of promoting connectivity and mobilizing revenues. A survey of the literature finds that limited telecoms competition likely creates rents that could efficiently be taxed. We propose a “pecking order” of sector-specific taxes that could be levied in addition to standard income and value-added taxes, based on capturing rents and minimizing distortions. Taxes that target possible economic rents or profits are preferable, but their administrative challenges may necessitate reliance on service excises at the cost of higher consumer prices and lower connectivity. Taxes on capital inputs and consumer access, which distort production and restrict network access, should be avoided; so should tax incentives, which are not needed to attract foreign capital to tap a local market.
Book Synopsis International VAT/GST Guidelines by : Collectif
Download or read book International VAT/GST Guidelines written by Collectif and published by OECD. This book was released on 2017-04-12 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) has become a major source of revenue for governments around the world. Some 165 countries operated a VAT at the time of the completion of the International VAT/GST Guidelines in 2016, more than twice as many as 25 years before. As VAT continued to spread across the world, international trade in goods and services has also expanded rapidly in an increasingly globalised economy. One consequence of these developments has been the greater interaction between VAT systems, along with growing risks of double taxation and unintended non-taxation in the absence of international VAT co-ordination. The International VAT/GST Guidelines now present a set of internationally agreed standards and recommended approaches to address the issues that arise from the uncoordinated application of national VAT systems in the context of international trade. They focus in particular on trade in services and intangibles, which poses increasingly important challenges for the design and operation of VAT systems worldwide. They notably include the recommended principles and mechanisms to address the challenges for the collection of VAT on cross-border sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project). These Guidelines were adopted as a Recommendation by the Council of the OECD in September 2016.
Book Synopsis Clusters in Automotive and Information & Communication Technology by : Paul J.J. Welfens
Download or read book Clusters in Automotive and Information & Communication Technology written by Paul J.J. Welfens and published by Springer Science & Business Media. This book was released on 2014-07-08 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Information & communication technology (ICT) and the automotive sector are two of the most important industries in the EU and the US. The EU’s eastern expansion and economic globalization have reinforced competition on the one hand; on the other hand the importance of outsourcing and off-shoring has increased. Against this background the intensification of innovation dynamics becomes crucial – and with them the role of regional innovation clusters. The analysis examines seven regions and six EU countries. The focus is on cluster and network dynamics in both industries, as regional ICT clusters are playing an increasingly central role in many European regions. Specialization and structural change in the automotive sector are highlighted, and new strategic approaches for multinational companies and changes in policy options are identified.
Book Synopsis Global Strategy and Practice of E-Governance: Examples from Around the World by : Piaggesi, Danilo
Download or read book Global Strategy and Practice of E-Governance: Examples from Around the World written by Piaggesi, Danilo and published by IGI Global. This book was released on 2011-04-30 with total page 564 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past decade, there has been continual development and renewal of strategies and practices surrounding e-governance. Governments around the world have embraced new information and communication technologies to increase the efficiency of internal processes, deliver better and more integrated services to citizens and businesses, invite citizen and stakeholder participation in planning decisions, improve communication, and sometimes even enhance democratic processes. Global Strategy and Practice of E-Governance: Examples from Around the World provides readers with an overview of relevant strategy and policy-level theoretical frameworks and examples, as well as up-to-date implementations from around the world. This book offers valuable insights into best practices, as well as some of the issues and challenges surrounding the governance of and with information and communication technologies in a globalized, knowledge-based world.
Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 1.
