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Oecd G20 Base Erosion And Profit Shifting Project Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances Action 6 2015 Final Report
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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 104 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 6.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-21 with total page 102 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report from the OECD/G20 Base Erosion and Profit Shifting project examines the issue of preventing the granting of treaty benefits in inappropriate circumstances. It includes proposed changes to the OECD Model Tax convention and summarises progress to date.
Book Synopsis Preventing Treaty Abuse by : Daniel Blum
Download or read book Preventing Treaty Abuse written by Daniel Blum and published by Linde Verlag GmbH. This book was released on 2016-09-19 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 48 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 7.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2022-03-21 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fourth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Book Synopsis Prevention of Treaty Abuse - Second Peer Review Report on Treaty Shopping by : Oecd
Download or read book Prevention of Treaty Abuse - Second Peer Review Report on Treaty Shopping written by Oecd and published by Org. for Economic Cooperation & Development. This book was released on 2021-03-16 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 82 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 5.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 48 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 14.
Book Synopsis Special Features of the UN Model Convention by : Anna Binder
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 664 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2019-02-14 with total page 264 pages. Available in PDF, EPUB and Kindle. Book excerpt: BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all Inclusive Framework members have committed to implement.This report reflects the outcome of the first peer review of the implementation ...
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, British Virgin Islands (Stage 2) Inclusive Framework on BEPS: Action 14 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, British Virgin Islands (Stage 2) Inclusive Framework on BEPS: Action 14 written by OECD and published by OECD Publishing. This book was released on 2022-04-14 with total page 57 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the British Virgin Islands.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2024-03-20 with total page 325 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the sixth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2023-03-21 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2016-08-26 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 456 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 2.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 192 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 Actions 8-10.
