Limitation on Benefits Clauses in Double Taxation Conventions

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041161430
Total Pages : 438 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Limitation on Benefits Clauses in Double Taxation Conventions by : Félix Alberto Vega Borrego

Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Transparencia fiscal internacional

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Author :
Publisher :
ISBN 13 : 9788480029827
Total Pages : 174 pages
Book Rating : 4.0/5 (298 download)

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Book Synopsis Transparencia fiscal internacional by : Ignacio Cruz Padial

Download or read book Transparencia fiscal internacional written by Ignacio Cruz Padial and published by . This book was released on 2000 with total page 174 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Combating Tax Avoidance in the EU

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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 and Development - A Comparative Study

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Author :
Publisher : Springer
ISBN 13 : 3319421573
Total Pages : 382 pages
Book Rating : 4.3/5 (194 download)

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Book Synopsis Taxation and Development - A Comparative Study by : Karen B. Brown

Download or read book Taxation and Development - A Comparative Study written by Karen B. Brown and published by Springer. This book was released on 2017-01-16 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.

EC Tax Review

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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:

Glosario Del Banco Mundial

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Publisher : World Bank Publications
ISBN 13 :
Total Pages : 468 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis Glosario Del Banco Mundial by : World Bank

Download or read book Glosario Del Banco Mundial written by World Bank and published by World Bank Publications. This book was released on 1996 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition of the World Bank has been revised and expanded by the Terminology Unit in the Languages Services Division of the World Bank in collaboration with the English, Spanish, and French Translation Sections. The Glossary is intended to assist the Bank's translators and interpreters, other Bank staff using French and Spanish in their work, and free-lance translator's and interpreters employed by the Bank. For this reason, the Glossary contains not only financial and economic terminology and terms relating to the Bank's procedures and practices, but also terms that frequently occur in Bank documents, and others for which the Bank has a preferred equivalent. Although many of these terms, relating to such fields as agriculture, education, energy, housing, law, technology, and transportation, could be found in other sources, they have been assembled here for ease of reference. A list of acronyms occurring frequently in Bank texts (the terms to which they refer being found in the Glossary) and a list of international, regional, and national organizations will be found at the end of the Glossary.

An Opportunity for a Different Peru

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Author :
Publisher : World Bank Publications
ISBN 13 : 082136863X
Total Pages : 860 pages
Book Rating : 4.8/5 (213 download)

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Book Synopsis An Opportunity for a Different Peru by : Marcelo Giugale

Download or read book An Opportunity for a Different Peru written by Marcelo Giugale and published by World Bank Publications. This book was released on 2007 with total page 860 pages. Available in PDF, EPUB and Kindle. Book excerpt: For the first time in the republican history of Peru, the presidential transition takes place in democracy, social peace, fast economic growth and favorable world markets. In other words, there has never been a better chance to build a different Peru - a richer country, more equal and governable. There are multiple ways to achieve that goal. New reforms must stem from a widespread and participatory debate, one of a common vision conceived for and by Peruvians. This book aims at making a technical and independent contribution to such debate; it summarizes the knowledge available about the challenges to be faced by the new administration. The study does not recommend silver bullets, but suggests policy options. It is based on the analysis of the current reality and in six decades of relationships with Peru, in which the Bank has implemented more than 100 projects and prepared more than 500 technical reports covering the wide range of development topics. When necessary, the study provides lessons that the Bank has learned elsewhere. The study provides a conceptual framework to the analysis of the country's 34 economic sectors and the two historical perspectives behind them. In doing so, it offers a comprehensive reform agenda that sheds light on possible priorities and courses of action.

Tax Challenges Arising from Digitalisation – Interim Report 2018

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Author :
Publisher : OECD
ISBN 13 : 9264301763
Total Pages : 260 pages
Book Rating : 4.2/5 (643 download)

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Book Synopsis Tax Challenges Arising from Digitalisation – Interim Report 2018 by : Collectif

Download or read book Tax Challenges Arising from Digitalisation – Interim Report 2018 written by Collectif and published by OECD. This book was released on 2018-05-29 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

Sociétés Transnationales

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Author :
Publisher : New York : United Nations
ISBN 13 :
Total Pages : 744 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Sociétés Transnationales by : United Nations Conference on Trade and Development. Programme on Transnational Corporations

Download or read book Sociétés Transnationales written by United Nations Conference on Trade and Development. Programme on Transnational Corporations and published by New York : United Nations. This book was released on 1993 with total page 744 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transparencia fiscal internacional

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Publisher :
ISBN 13 : 9788445407622
Total Pages : 376 pages
Book Rating : 4.4/5 (76 download)

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Book Synopsis Transparencia fiscal internacional by : Eduardo Sanz Gadea

Download or read book Transparencia fiscal internacional written by Eduardo Sanz Gadea and published by . This book was released on 1996-01-01 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The North American Mosaic

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Publisher :
ISBN 13 :
Total Pages : 240 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis The North American Mosaic by : Commission for Environmental Cooperation (Montréal, Québec). Secretariat

Download or read book The North American Mosaic written by Commission for Environmental Cooperation (Montréal, Québec). Secretariat and published by . This book was released on 2001 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: The North American Mosaic has four overarching features. First, it is, to the extent feasible, based on comparable information on the status and trends of major indicators of the state of the environment in Canada,Mexico, and the United States. Second, the report confirms that these three countries together make up an incredibly complex, dynamic, and interconnected ecosystem in which humans play a dominant and decisive role. Third, the report raises important and sometimes disquieting questions concerning the sustainability of some current trends. Finally, the report is a reminder that our economic, social, and physical well-being are utterly dependent on the life-sustaining services provided by nature. This report emphasizes the importance of developing mutually compatible economic, social, and environmental goals and policies across the three-country region.

Permanent Establishment

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403520647
Total Pages : 999 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Permanent Establishment by : Arvid Aage Skaar

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 999 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.

Governing the Metropolis

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Publisher : David Rockefeller Center for Latin American Studies
ISBN 13 :
Total Pages : 332 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Governing the Metropolis by : Eduardo Rojas

Download or read book Governing the Metropolis written by Eduardo Rojas and published by David Rockefeller Center for Latin American Studies. This book was released on 2008 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores key metropolitan management issues, presents practical principles of good governance as they apply to the metropolis, and unfolds cases of institutional and programmatic arrangements to tackle such issues.

Employment in Metropolitan Areas

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Publisher :
ISBN 13 :
Total Pages : 126 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis Employment in Metropolitan Areas by : United States. Bureau of Labor Statistics

Download or read book Employment in Metropolitan Areas written by United States. Bureau of Labor Statistics and published by . This book was released on 1947 with total page 126 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition

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Publisher : OECD Publishing
ISBN 13 : 9264267999
Total Pages : 326 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition by : OECD

Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

Food and Agricultural Development

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Author :
Publisher :
ISBN 13 :
Total Pages : 20 pages
Book Rating : 4.E/5 ( download)

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Book Synopsis Food and Agricultural Development by : United States. Agency for International Development

Download or read book Food and Agricultural Development written by United States. Agency for International Development and published by . This book was released on 1982 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:

A Beneficial Ownership Implementation Toolkit

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Author :
Publisher : Inter-American Development Bank
ISBN 13 :
Total Pages : 51 pages
Book Rating : 4./5 ( download)

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Book Synopsis A Beneficial Ownership Implementation Toolkit by : Organization for Economic Cooperation and Development

Download or read book A Beneficial Ownership Implementation Toolkit written by Organization for Economic Cooperation and Development and published by Inter-American Development Bank. This book was released on 2019-05-21 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2016, the G20 called on the FATF and the Global Forum to propose ways to improve the implementation of the international standards on transparency, including on the availability of beneficial ownership information, and its international exchange. The Global Forum developed a framework of proposed actions to answer that call, including a plan to facilitate effective implementation through examples of good implementation and technical assistance. This toolkit is in furtherance of the Global Forum’s commitment to support countries’ effective implementation. It is intended to help jurisdictions to develop an understanding of the beneficial ownership concepts contained in the international standards of transparency and exchange of information, and for use in conjunction with technical assistance seminars. It will support policy and implementation discussions in conjunction with capacity building workshops and technical assistance activities carried out by the Global Forum Secretariat as well as other supporting international organizations.