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Oecd G20 Base Erosion And Profit Shifting Project Prevention Of Treaty Abuse Peer Review Report On Treaty Shopping Inclusive Framework On Beps Action 6
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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 Treaty Abuse – Second 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 – Second 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 2020-03-24 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 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 members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the second peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
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 266 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 Harmful Tax Competition An Emerging Global Issue by : OECD
Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
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 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 24 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 Addressing Base Erosion and Profit Shifting by : OECD
Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
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 Prevention of Tax Treaty Abuse – Third 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 – Third 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 2021-04-01 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 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 members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
Book Synopsis A Multilateral Convention for Tax by : Sergio André Rocha
Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
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 537 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.
Book Synopsis Essays on International Taxation by : Dhruv Sanghavi
Download or read book Essays on International Taxation written by Dhruv Sanghavi and published by Bloomsbury Publishing. This book was released on 2020-12-21 with total page 530 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
Book Synopsis Introduction to United States International Taxation by : James R. Repetti
Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
Book Synopsis Big Data Analysis on Global Community Formation and Isolation by : Yuichi Ikeda
Download or read book Big Data Analysis on Global Community Formation and Isolation written by Yuichi Ikeda and published by Springer Nature. This book was released on 2021-06-12 with total page 509 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this book, the authors analyze big data on global interdependence caused by the flows of commodities, money, and people, using a network science approach to obtain differing views of globalization and to clarify the facts on isolation of communities. Globalization reduces international economic inequality, i.e., it allows emerging countries to catch up while it increases relative poverty in some advanced countries. How should this trade-off between international and domestic inequalities be resolved? At the same time, the reduction of biocultural diversity caused by globalization needs to be avoided. What kind of change is required in local communities to conserve biocultural diversity? On the issue of commodity flow, research results of the supply-chain network, isolation in industry, and resource flows and stocks are presented in this book. For monetary flow, ownership networks, value-added networks, and profit shifting were studied; and regarding the flow of people, linkage of ethnic groups, immigrant assimilation, and refugees were examined. Based on the resulting view of globalization and isolation, the development of the isolation index using machine learning is discussed. Finally, recommendations for evidence-based policymaking in the United Nations are considered.
Book Synopsis Concept and Implementation of CFC Legislation by : Nathalie Bravo
Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Book Synopsis Prevention of Tax Treaty Abuse - Fourth Peer Review Report on Treaty Shopping by : Oecd
Download or read book Prevention of Tax Treaty Abuse - Fourth Peer Review Report on Treaty Shopping written by Oecd and published by . This book was released on 2022-03-21 with total page 316 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. It includes the aggregate results of the review and data on tax treaties concluded by each of the 139 members of the OECD/G20 Inclusive Framework on BEPS on 31 May 2021, and also contains the jurisdictional section for each member. This is the first peer review process governed by a revised peer review methodology
Book Synopsis Tax Policy Reforms 2024 OECD and Selected Partner Economies by : OECD
Download or read book Tax Policy Reforms 2024 OECD and Selected Partner Economies written by OECD and published by OECD Publishing. This book was released on 2024-09-30 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the ninth edition of Tax Policy Reforms: OECD and Selected Partner Economies, an annual publication that provides comparative information on tax reforms across countries and tracks tax policy developments over time. The report covers the tax policy reforms introduced or announced in 2023 in 90 member jurisdictions of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting, including all OECD countries. The publication provides an overview of the macroeconomic environment and tax revenue context in which these tax reforms were made, highlighting how governments used tax policy to respond to elevated inflation levels, as well as to address long-run structural challenges.
