Permanent Establishmentsa Planning Primer

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Permanent Establishments:A Planning Primer

Author : John Huston
Publisher : Springer
ISBN 13 :
Total Pages : 212 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Permanent Establishments:A Planning Primer by : John Huston

Download or read book Permanent Establishments:A Planning Primer written by John Huston and published by Springer. This book was released on 1993-08-19 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a comprehensive review of the tax treaty concept of a `permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the `fixed place of business' and `dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.

How Fixed Is a Permanent Establishment?

Author : Jean Schaffner
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041146660
Total Pages : 344 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis How Fixed Is a Permanent Establishment? by : Jean Schaffner

Download or read book How Fixed Is a Permanent Establishment? written by Jean Schaffner and published by Kluwer Law International B.V.. This book was released on 2013-02-01 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question ‘Is there a permanent establishment?’ is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a ‘fixed link to the ground’, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: Is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus? Drawing on case law, administrative practice, and business decisions in numerous jurisdictions, the author discusses the permanent establishment criteria under conditions of e-commerce and the service economy. He shows that the OECD Model Convention and its commentaries already offer the basis for the evolution of the analysis of the concept, and that the preservation of permanent establishment protects and maintains the level playing field between capital importing and capital exporting economies. He examines in depth such elements as the following: ;the prevalence of commercial coherence over geographic coherence; the role of value-added tax; services permanent establishment; relevant definitions of ‘activity’ and ‘personnel’; multiple permanent establishments; supervision activity and sub-contracting; the differences between civil law and common law concepts of representation; particular treatment of the insurance sector; the ‘force of attraction’ concept; and specific exceptions (e.g., transportation, artists and sportsmen, rental income, agricultural activities, pipelines). Taking into account important distinctions between two model conventions (OECD and UN), as well as pertinent EU directives and the impact of EU law, the author proposes minor amendments to the OECD Model that adapt it to economic reality and current trends in jurisprudence and that can be implemented immediately. An appendix includes Article 5 and its commentaries as they have evolved since 1963, with the successive addenda and deletions. The author’s 20-plus years of experience as a tax lawyer lend the presentation a thoroughly practical aspect. The work addresses in more detail than any other publication the topic of profit allocation to a permanent establishment in the e-commerce world, an issue which is evolving rapidly in the current economic environment. Tax advisors, lawyers, and interested academics and policymakers will benefit from the book’s clear analysis of the conditions under which a permanent establishment not only should be preserved, but also how it is likely to be adapted in the future.

Permanent Establishment

Author : Arvid Aage Skaar
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403520647
Total Pages : 957 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 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.

Permanent Establishments

Author : Ekkehart Reimer
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041190759
Total Pages : 850 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Permanent Establishments by : Ekkehart Reimer

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.

Dependent Agents as Permanent Establishments

Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 3709405432
Total Pages : 452 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Dependent Agents as Permanent Establishments by : Michael Lang

Download or read book Dependent Agents as Permanent Establishments written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2014-07-04 with total page 452 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dependent Agents as Permanent Establishments The article on business profits may be the most relevant one in tax treaties. If patterned after the OECD Model Tax Convention, this article allocates the exclusive taxing right over the profits of an enterprise to the residence country, unless the enterprise carries on business in the source country through a permanent establishment. Considering the importance of allocating taxation rights, tax authorities and courts of many countries have increasingly focused on the concept of agency permanent establishment. This book includes 12 chapters which provide an in-depth analysis of the key aspects that need to be taken into account for interpreting the concept of agency permanent establishment. It incorporates the perspectives of leading scholars and practitioners dealing with international tax cases. This book is designed to provide essential insights to academics, practitioners, tax officials and judges who deal or are interested in the field of international taxation.

Special Features of the UN Model Convention

Author : Anna Binder
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410401
Total Pages : 582 pages
Book Rating : 4.7/5 (94 download)

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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 582 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.

Klaus Vogel on Double Taxation Conventions

Author : Ekkehart Reimert
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403512849
Total Pages : 3112 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Klaus Vogel on Double Taxation Conventions by : Ekkehart Reimert

Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University

E-commerce and Source-based Income Taxation

Author : Dale Pinto
Publisher : IBFD
ISBN 13 : 9076078564
Total Pages : 260 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis E-commerce and Source-based Income Taxation by : Dale Pinto

Download or read book E-commerce and Source-based Income Taxation written by Dale Pinto and published by IBFD. This book was released on 2003 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.

IBFD International Tax Glossary

Author : Julie Rogers-Glabush
Publisher : IBFD
ISBN 13 : 908722057X
Total Pages : 561 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis IBFD International Tax Glossary by : Julie Rogers-Glabush

Download or read book IBFD International Tax Glossary written by Julie Rogers-Glabush and published by IBFD. This book was released on 2009 with total page 561 pages. Available in PDF, EPUB and Kindle. Book excerpt: Authoritative resource for defining tax and tax-related terms. With the addition of over 120 completely new definitions and over 100 substantially revised descriptions, this edition contains more than 2,000 tax terms, clearly and concisely defined in English; alphabetical listing of some 400 English terms together with their French, German, Spanish and Dutch equivalents; cross-referenced listing of terms indicating similar, related and contrasting terms; abbreviations and bibliographical references to aid further research; a list of tax-related organizations, with brief descriptions and Internet addresses; accurate descriptions of both traditional and more obscure terms; expanded coverage of terms relating to customs, VAT, capital taxes, transfer pricing and EU tax law terminology; a separate extensive list of tax-related organizations in some 40 countries.

Tiley’s Revenue Law

Author : Glen Loutzenhiser
Publisher : Bloomsbury Publishing
ISBN 13 : 1509921354
Total Pages : 1647 pages
Book Rating : 4.5/5 (99 download)

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Book Synopsis Tiley’s Revenue Law by : Glen Loutzenhiser

Download or read book Tiley’s Revenue Law written by Glen Loutzenhiser and published by Bloomsbury Publishing. This book was released on 2019-08-22 with total page 1647 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf

International Taxation of Income from Services under Double Taxation Conventions

Author : Marta Castelon
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041195955
Total Pages : 544 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Taxation of Income from Services under Double Taxation Conventions by : Marta Castelon

Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 544 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

International Tax Primer

Author : Brian J. Arnold
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041159819
Total Pages : 275 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Tax Primer by : Brian J. Arnold

Download or read book International Tax Primer written by Brian J. Arnold and published by Kluwer Law International B.V.. This book was released on 2016-01-21 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. This third edition has been expanded substantially, due to the major developments that have occurred since the second edition of this indispensable resource appeared in 2004 – not least the fact that innumerable smalland medium-sized firms, as well as individuals, now engage in cross-border transactions that cause them and their tax advisers to confront international tax issues on a regular basis. Moreover, as the countries of the world have become increasingly integrated economically, the importance of the major issues that a country must confront in designing its international tax rules and in coordinating those rules with the tax systems of its trading partners has mushroomed. The book strikes a balance between the specific and the general by illustrating the funda mental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of non-residents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN • Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. New material in the third edition includes analysis of the OECD’s initiative against base erosion and profit shifting (BEPS), tax aspects of hybrid entities and financial instruments, and taxation of fees for technical services as proposed under the UN Model Treaty. Although of greatest value to tax practitioners and government officials confronting interna tional tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.

EC Tax Review

Author :
Publisher :
ISBN 13 :
Total Pages : 1032 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 1992 with total page 1032 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Advanced Topics in Revenue Law

Author : John Tiley
Publisher : Bloomsbury Publishing
ISBN 13 : 1782250395
Total Pages : 537 pages
Book Rating : 4.7/5 (822 download)

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Book Synopsis Advanced Topics in Revenue Law by : John Tiley

Download or read book Advanced Topics in Revenue Law written by John Tiley and published by Bloomsbury Publishing. This book was released on 2013-01-07 with total page 537 pages. Available in PDF, EPUB and Kindle. Book excerpt: The last several years have seen fundamental changes to the UK tax system. Nearly the entirety of the UK corporation tax and international tax rules have been rewritten by three new statutes – the Corporation Tax Acts 2009 and 2010 and the Taxation (International and Other Provisions) Act 2010. The UK has also implemented major new policies affecting the taxation of pensions, charities, savings vehicles, 'non-doms' and the foreign profits of UK companies. In addition, European Union law, and especially the case law of the Court of Justice of the European Union, has had an increasingly important impact on UK corporation tax and international tax law in particular. This new book on advanced topics in UK tax law is derived from material previously found in John Tiley's major text on Revenue Law that has been expanded and comprehensively updated to take account of these developments. The book deals with Corporation Tax, International and European Tax, Savings and Charities, in a manageable and portable volume for law students and practitioners. It complements the material on UK Income Tax, Capital Gains Tax, and Inheritance Tax found in Revenue Law, 7th edition. Unlike other tax law books, this text explains the new rules found in CTA 2009, CTA 2010 and TIOPA 2010 in light of its legislative predecessors. The book contains extensive references to the new legislation and also to the former enactments in ICTA 1988 and elsewhere. Those familiar with the old law but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking advanced tax courses in the final year of their law degree course and for graduate students, but is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of or reference to the background material in terms of policy, history or other countries' tax systems.

Introduction to Cyprus Law

Author : Dennis Campbell
Publisher :
ISBN 13 :
Total Pages : 1034 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Introduction to Cyprus Law by : Dennis Campbell

Download or read book Introduction to Cyprus Law written by Dennis Campbell and published by . This book was released on 2000 with total page 1034 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Canadian Tax Journal

Author :
Publisher :
ISBN 13 :
Total Pages : 2516 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Canadian Tax Journal by :

Download or read book Canadian Tax Journal written by and published by . This book was released on 1995 with total page 2516 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of Permanent Establishments

Author : Robert L. Williams
Publisher : Kluwer Law International
ISBN 13 : 9789041149480
Total Pages : 0 pages
Book Rating : 4.1/5 (494 download)

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Book Synopsis Fundamentals of Permanent Establishments by : Robert L. Williams

Download or read book Fundamentals of Permanent Establishments written by Robert L. Williams and published by Kluwer Law International. This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.