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International Taxation In A Changing Landscape
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Book Synopsis International Taxation in a Changing Landscape by : Jérôme Monsenego
Download or read book International Taxation in a Changing Landscape written by Jérôme Monsenego and published by Kluwer Law International B.V.. This book was released on 2019-05-31 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Prof. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax law, with a major focus on corporate taxation, an area to which Prof. Dr Bertil Wiman has dedicated most of his research. The book includes authoritative analyses by acknowledged experts on several key international tax topics, which illustrates the growing complexity of this area together with its rapid evolution. The book contains analyses of key international topics, such as: the tax challenges of the digitalisation of the economy; the resolution of international tax disputes; the principles for the taxation of corporations; EU tax law; transfer pricing; and tax treaty law. The depth of the essays contained in this book mirrors the importance of the contributions of Prof. Dr Bertil Wiman to the international tax community. It will also prove of great value to policymakers, tax practitioners and academics.
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.
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Book Synopsis International Law of Taxation by : Peter Hongler
Download or read book International Law of Taxation written by Peter Hongler and published by Oxford University Press. This book was released on 2021 with total page 289 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.
Book Synopsis Research Handbook on International Taxation by : Yariv Brauner
Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Author :Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs Publisher :Paris, France : Organisation for Economic Co-operation and Development ; [Washington, D.C. : Sales agents, OECD Publications and Information Center] ISBN 13 : Total Pages :212 pages Book Rating :4.3/5 (91 download)
Book Synopsis Taxes on Immovable Property by : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Download or read book Taxes on Immovable Property written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Paris, France : Organisation for Economic Co-operation and Development ; [Washington, D.C. : Sales agents, OECD Publications and Information Center]. This book was released on 1983 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: Survey of taxes on immovable property. Reviews the major policy issues raised in the taxation of land and buildings and compares the main provision of property tax systems in 15 OECD Member countries.
Book Synopsis International Taxation of Banking by : John Abrahamson
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Book Synopsis A Journey Through European and International Taxation by : Carla De Pietro
Download or read book A Journey Through European and International Taxation written by Carla De Pietro and published by Kluwer Law International B.V.. This book was released on 2024-03-06 with total page 625 pages. Available in PDF, EPUB and Kindle. Book excerpt: To some extent, because of his overlapping careers in academia and politics, the renowned tax scholar Peter Essers is known for his influential insight that ‘the effects of taxation on the political balance of power, and vice versa, are always interlinked with other phenomena, such as wars, crises, religious developments and inequalities in society’. In this widely ranging festschrift, thirty-six prominent tax scholars from all across Europe examine the legacy of Peter Essers’ research interests, from the larger philosophical, political, and social factors driving tax history to the reality of the taxing State as experienced by taxpayers and tax officials. The book’s outstanding overview of the most relevant technical and policy aspects of European and international taxation includes deeply thoughtful chapters on such topics and issues as the following: developing sustainable corporate tax governance; tax whistleblowing; transfer pricing; balancing qualitative and quantitative approaches to tax research; necessity to reach something close to ‘equal treatment’ between the upper and lower social classes; consent and democracy; tax rebellions; tax evasion and tax avoidance; taxation of cross-border remote workers and their employers; mitigation of double taxation of income earned by entertainers and sportspersons; and the international tax treaty network. More than a homage to this scholar’s far-reaching contributions, this book is remarkable for the variety and academic rigour of the chapters. The understanding its authors provide of both the broad contours and the intricacies of European and international taxation will be of inestimable value to tax practitioners, policymakers, tax consultants, and academics, as well as interested researchers in economics, political science, and sociology.
Book Synopsis International Tax Policy by : Tsilly Dagan
Download or read book International Tax Policy written by Tsilly Dagan and published by Cambridge University Press. This book was released on 2018 with total page 263 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.
Book Synopsis TALIS 2018 Results (Volume I) Teachers and School Leaders as Lifelong Learners by : OECD
Download or read book TALIS 2018 Results (Volume I) Teachers and School Leaders as Lifelong Learners written by OECD and published by OECD Publishing. This book was released on 2019-06-19 with total page 220 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Teaching and Learning International Survey (TALIS) is the largest international survey asking teachers and school leaders about their working conditions and learning environments, and provides a barometer of the profession every five years. Results from the 2018 cycle explore and examine the various dimensions of teacher and school leader professionalism across education systems.
Book Synopsis Imposing Standards by : Martin Hearson
Download or read book Imposing Standards written by Martin Hearson and published by Cornell University Press. This book was released on 2021-06-15 with total page 162 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Imposing Standards, Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits on the ability of developing countries to tax businesses, denying the Global South access to much-needed revenue. The international rules that allow tax avoidance by multinational corporations have dominated political debate about international tax in the United States and Europe, especially since the global financial crisis of 2007–2008. Hearson asks how developing countries willingly gave up their right to tax foreign companies, charting their assimilation into an OECD-led regime from the days of early independence to the present day. Based on interviews with treaty negotiators, policymakers and lobbyists, as well as observation at intergovernmental meetings, archival research, and fieldwork in Africa and Asia, Imposing Standards shows that capacity constraints and imperfect negotiation strategies in developing countries were exploited by capital-exporting states, shielding multinationals from taxation and depriving nations in the Global South of revenue they both need and deserve. Thanks to generous funding from the Gates Foundation, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.
Book Synopsis The Resolution of International Tax Disputes by : David Rüll
Download or read book The Resolution of International Tax Disputes written by David Rüll and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Book Synopsis International Investment Law: A Changing Landscape A Companion Volume to International Investment Perspectives by : OECD
Download or read book International Investment Law: A Changing Landscape A Companion Volume to International Investment Perspectives written by OECD and published by OECD Publishing. This book was released on 2005-09-06 with total page 166 pages. Available in PDF, EPUB and Kindle. Book excerpt: Presents four studies on international investment law: one on transparency, one on the fair and equitable treatment standard, one on indirect expropriation and the right to regulate, and one on most favoured nation treatment.
Book Synopsis The Oxford Handbook of International Tax Law by : Florian Haase
Download or read book The Oxford Handbook of International Tax Law written by Florian Haase and published by Oxford University Press. This book was released on 2023 with total page 1185 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
Book Synopsis Tax Sovereignty and the Law in the Digital and Global Economy by : Francesco Farri
Download or read book Tax Sovereignty and the Law in the Digital and Global Economy written by Francesco Farri and published by Routledge. This book was released on 2020-09-27 with total page 249 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses which is the most appropriate tax dimension to best manage the new horizons of the global and digital economy. In this perspective, the efficiency of the main models is examined and two fundamental proposals are put forth: the first one aims at a coordination of the Destination-Based approach with the role of some specific digital assets, such as user data; the second one is a framework for a possible futuristic tax phenomenon all internal to the world of the internet and not linked to traditional territorial States. The compliance of these models with the constitutional principles that western democratic systems have affirmed over time in matters of taxation is then analyzed with particular regard to legal certainty, consent to taxation and to the re-distributive function of taxes. A specific evaluation of the role of the European Union is carried out and the jurisprudence on financial interests of the Union and on State aids is analyzed and tackled in light of the Treaty on the Functioning of the European Union and of the tax sovereignty of member States. The conclusion is that the model of the organization with a general political purpose, from which modern States take their inspiration, appears unfailing for a tax project that would focus on the good and the growth of the person and of the social aggregations in which everyone lives. A model that therefore deserves to be safeguarded, although with new methods and instruments, starting from a Destination-Based Asset-Coordinated approach, in the Third Millennium. The book will be of interest to researchers and academics in international tax law, constitutional law and in political science.
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.
Book Synopsis Double non-taxation and the use of hybrid entities by : Leopoldo Parada
Download or read book Double non-taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
