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Author : Che Chun Liu
Publisher :
ISBN 13 :
Total Pages : 22 pages
Book Rating : 4.:/5 (417 download)
Download or read book Japanese Concept of P.E. & U.S.-Japan Tax Treaty written by Che Chun Liu and published by . This book was released on 1985 with total page 22 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : U. S. Government
Publisher :
ISBN 13 : 9781522032755
Total Pages : 82 pages
Book Rating : 4.0/5 (327 download)
Download or read book U. S. - Japan Tax Treaty written by U. S. Government and published by . This book was released on 2017-08-06 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: CONVENTION BETWEENTHE GOVERNMENT OF THE UNITED STATES OF AMERICA ANDTHE GOVERNMENT OF JAPANFOR THE AVOIDANCE OF DOUBLE TAXATIONAND THE PREVENTION OF FISCAL EVASIONWITH RESPECT TO TAXES ON INCOMEThe Government of the United States of America and the Government of Japan,Desiring to conclude a new Convention for the avoidance of double taxation and theprevention of fiscal evasion with respect to taxes on income.
Author : U. S. Department U.S. Department of the Treasury
Publisher :
ISBN 13 : 9781503130562
Total Pages : 116 pages
Book Rating : 4.1/5 (35 download)
Download or read book Japan: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention between the Government of the United States of America and the Government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Washington on November 6, 2003 (the "Convention"), and the Protocol also signed at Washington on November 6, 2003, which forms an integral part thereto (the "Protocol"). In connection with the negotiation of the Convention, the delegations of the United States and Japan developed and agreed upon an exchange of Diplomatic Notes (the "Notes"). The Notes constitute an agreement between the two governments that shall enter into force at the same time as the entry into force of the Convention. The Notes are intended to give guidance both to the taxpayers and to the tax authorities of the Contracting States in interpreting the Convention. The Notes and Protocol are discussed below in connection with relevant provisions of the Convention. References are made to the Convention between the Government of the United States of America and the Government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Tokyo on March 8, 1971 (the "prior Convention"). The Convention and Protocol replace the prior Convention. Negotiations took into account the U.S. Treasury Department's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on September 20, 1996 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in January 2003 (the "OECD Model"), and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. While the Convention does not include subject matter headings or titles for the Articles, such headings are included in the Technical Explanation for ease of use. The headings included generally correspond to headings of analogous articles of the U.S. Model where possible, and it is not intended that any legal effect be given to the headings or to the fact of their inclusion in the Technical Explanation. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her."
Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 370940911X
Total Pages : 332 pages
Book Rating : 4.7/5 (94 download)
Download or read book Tax Treaty Case Law around the Globe 2017 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2018-02-20 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided in 2016 around the world.
Author : Florian Haase
Publisher : Oxford University Press
ISBN 13 : 0192652346
Total Pages : 1185 pages
Book Rating : 4.1/5 (926 download)
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 2023-09-22 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.
Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087221010
Total Pages : 675 pages
Book Rating : 4.0/5 (872 download)
Download or read book The Meaning of "enterprise", "business" and "business Profits" Under Tax Treaties and EU Tax Law written by Guglielmo Maisto and published by IBFD. This book was released on 2011 with total page 675 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Meaning of "Enterprise", "Business" and "Business Profits" under Tax Treaties and EU Tax Law, comprising the proceedings and working documents of an annual seminar held in Milan in November 2010, provides an in-depth analysis of the meaning of these three essential concepts in relevant tax treaties and law. The analysis starts from an EU tax law perspective, with a particular emphasis on the European Directives. The above concepts are then considered from domestic tax law viewpoints. The book then moves to tax treaty law. Most notably, an examination of the history and interpretation of the concepts of "enterprise", "business" and "business profits" is presented, starting from the works of the League of Nations to the current OECD Model Tax Convention. Next, specific tax treaty issues are considered. In particular, the controversial issues concerning the interpretation of the notions of "enterprise" and "enterprise of a Contracting State" are discussed. Also, the concepts of "profits" and "business profits" are thoroughly reviewed. The concept of "enterprise" in the context of the non-discrimination clause laid down by Art. 24 of the OECD Model Tax Convention is then examined. Individual country surveys provide an in-depth analysis of the aforementioned concepts and issues from a national viewpoint in selected European and North American jurisdictions, as well as in Australia and Japan. The book concludes with a round-table discussion among some of the most renowned international tax scholars on the desirability to change the OECD Model Tax Convention and its Commentaries. This book is essential reading for all those dealing with issues of taxation of enterprises engaged in cross-border activities and can be considered a new cornerstone in the subject matter."--Publisher's website
Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1108150381
Total Pages : 2216 pages
Book Rating : 4.1/5 (81 download)
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Author :
Publisher :
ISBN 13 :
Total Pages : 128 pages
Book Rating : 4.:/5 (327 download)
Download or read book Explanation of Proposed Income Tax Treaty Between the United States and Japan written by and published by . This book was released on 2004 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Yukiyasu Nakata
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403543116
Total Pages : 283 pages
Book Rating : 4.4/5 (35 download)
Download or read book Q&A on Japanese Taxation for Multinational Corporations written by Yukiyasu Nakata and published by Kluwer Law International B.V.. This book was released on 2022-07-08 with total page 283 pages. Available in PDF, EPUB and Kindle. Book excerpt: Given its prominence among the world’s major industrial jurisdictions, Japan is involved in numerous multinational corporate transactions, and its extensive and complex tax regime inevitably plays an important role. This unique book, with its easy-to-use Q&A format, provides succinct and authoritative responses to most of the questions that tax professionals operating in or doing business with Japan are likely to face in practice. The author, a well-known Japanese international tax specialist, has organised eighty-seven questions around tax issues he has consulted on over more than twenty years of direct experience in advising international businesses. The questions, all based on actual examples, cover every area of tax practice, including the following: tax notifications upon establishment of a Japanese company; foreign tax credits; transfer pricing documentation obligations; tax treatment of small- and medium-sized enterprises; exemption from withholding tax for Japanese branches of foreign corporations; withholding tax on royalties for trademarks and relief under tax conventions; withholding tax on directors’ remuneration paid to non-resident directors; maintenance of electronic accounting books and records; tax treatment of bad debt losses; deductibility of entertainment expenses; sales and purchases of goods located in Japan by a foreign corporation; and tax treatment of the cross-border supply of electronic services. The English translations of terms used in Japanese taxation and tax practice are designed to facilitate understanding for non-Japanese tax practitioners. As an overview of Japanese tax issues that may be faced in the realm of international business, this incomparable book provides tax professionals with a wealth of expertise that may be readily applied to any tax strategy involving a business transaction with a Japanese element. It will be welcomed by in-house corporate counsel, taxation academics, and tax lawyers worldwide.
Author :
Publisher :
ISBN 13 :
Total Pages : 214 pages
Book Rating : 4.F/5 ( download)
Download or read book Tax Management Portfolios written by and published by . This book was released on 2006 with total page 214 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Ernest R. Larkins
Publisher : John Wiley & Sons
ISBN 13 : 0471482811
Total Pages : 456 pages
Book Rating : 4.4/5 (714 download)
Download or read book International Applications of U.S. Income Tax Law written by Ernest R. Larkins and published by John Wiley & Sons. This book was released on 2003-11-20 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
Author : Eric Kemmeren
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410061
Total Pages : 478 pages
Book Rating : 4.7/5 (94 download)
Download or read book Tax Treaty Case Law around the Globe 2018 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2019-06-13 with total page 478 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 35 most important tax treaty cases which were decided around the world in 2017. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2018 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Author : Arvid Aage Skaar
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403520647
Total Pages : 957 pages
Book Rating : 4.4/5 (35 download)
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Author :
Publisher :
ISBN 13 :
Total Pages : 332 pages
Book Rating : 4.:/5 (318 download)
Download or read book Bulletin for International Taxation written by and published by . This book was released on 2007 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Netherlands
Publisher :
ISBN 13 :
Total Pages : 24 pages
Book Rating : 4.:/5 (319 download)
Download or read book Tax Convention with the Netherlands written by Netherlands and published by . This book was released on 1969 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Ekkehart Reimer
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041190759
Total Pages : 850 pages
Book Rating : 4.0/5 (411 download)
Download or read book Permanent Establishments written by Ekkehart Reimer and published by Kluwer Law International B.V.. This book was released on 2018-06-07 with total page 850 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
Author : Ms. Era Dabla-Norris
Publisher : International Monetary Fund
ISBN 13 : 1513577425
Total Pages : 75 pages
Book Rating : 4.5/5 (135 download)
Download or read book Digitalization and Taxation in Asia written by Ms. Era Dabla-Norris and published by International Monetary Fund. This book was released on 2021-09-14 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.
