Principles of International Taxation

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Author :
Publisher : Bloomsbury Publishing
ISBN 13 : 1526519577
Total Pages : 709 pages
Book Rating : 4.5/5 (265 download)

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Book Synopsis Principles of International Taxation by : Lynne Oats

Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 709 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.

Permanent Establishment

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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.

Business Taxation and Financial Decisions

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Publisher : Springer Science & Business Media
ISBN 13 : 3642032842
Total Pages : 415 pages
Book Rating : 4.6/5 (42 download)

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Book Synopsis Business Taxation and Financial Decisions by : Deborah Schanz

Download or read book Business Taxation and Financial Decisions written by Deborah Schanz and published by Springer Science & Business Media. This book was released on 2010-10-17 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: Managerial decisions are considerably influenced by taxes: e.g. the choice of location, buying or leasing decisions, or the proper mix of debt and equity in the company's capital structure increasingly demand qualified employees in an economic environment that is becoming more and more complex. Due to the worldwide economic integration and constant changes in tax legislation, companies are faced with new challenges – and the need for information and advice is growing accordingly. This book's goal is to identify and quantify possible tax effects on companies' investment strategies and financing policies. It does not focus on details of tax law, but instead seeks to address students and practitioners focusing on corporate finance, accounting, investment banking and strategy consulting.

The S Corporation Answer Book

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Publisher : Wolters Kluwer
ISBN 13 : 0735581517
Total Pages : 824 pages
Book Rating : 4.7/5 (355 download)

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Book Synopsis The S Corporation Answer Book by : Sydney S. Traum

Download or read book The S Corporation Answer Book written by Sydney S. Traum and published by Wolters Kluwer. This book was released on 2008-12-17 with total page 824 pages. Available in PDF, EPUB and Kindle. Book excerpt: This quick-reference manual lets you help clients take full advantage of their S corporation status and minimize their taxes. it leads you directly to authoritative information on every aspect of the S corporation, enabling you to: Arm the S corporation against the potential tax traps hidden in the Small Business Tax Protection Act. Maximize the tax benefits of S corporation status. Make a qualified Subchapter S Subsidiary (QSub) election. Identify dispositions that will trigger the built-in gains tax. Avoid added tax liability or loss of S corporation status from passive investment income. Capitalize on the permissible differences in stock rights to facilitate estate planning and ownership transfers. Determine allocation of income, losses, and deductions in the termination year of the S corporation . Plus, there are citations To The controlling rules, regulations, and court decisions that will save you hours of research.

Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 940350644X
Total Pages : 254 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle by : Eva Escribano

Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Profit First

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Author :
Publisher : Penguin
ISBN 13 : 073521414X
Total Pages : 225 pages
Book Rating : 4.7/5 (352 download)

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Book Synopsis Profit First by : Mike Michalowicz

Download or read book Profit First written by Mike Michalowicz and published by Penguin. This book was released on 2017-02-21 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: Author of cult classics The Pumpkin Plan and The Toilet Paper Entrepreneur offers a simple, counterintuitive cash management solution that will help small businesses break out of the doom spiral and achieve instant profitability. Conventional accounting uses the logical (albeit, flawed) formula: Sales - Expenses = Profit. The problem is, businesses are run by humans, and humans aren't always logical. Serial entrepreneur Mike Michalowicz has developed a behavioral approach to accounting to flip the formula: Sales - Profit = Expenses. Just as the most effective weight loss strategy is to limit portions by using smaller plates, Michalowicz shows that by taking profit first and apportioning only what remains for expenses, entrepreneurs will transform their businesses from cash-eating monsters to profitable cash cows. Using Michalowicz's Profit First system, readers will learn that: · Following 4 simple principles can simplify accounting and make it easier to manage a profitable business by looking at bank account balances. · A small, profitable business can be worth much more than a large business surviving on its top line. · Businesses that attain early and sustained profitability have a better shot at achieving long-term growth. With dozens of case studies, practical, step-by-step advice, and his signature sense of humor, Michalowicz has the game-changing roadmap for any entrepreneur to make money they always dreamed of.

International Business Taxation

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Author :
Publisher : Praeger
ISBN 13 :
Total Pages : 424 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis International Business Taxation by : Sol Picciotto

Download or read book International Business Taxation written by Sol Picciotto and published by Praeger. This book was released on 1992-03-02 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

International Company Taxation

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Publisher : Springer Science & Business Media
ISBN 13 : 3642363067
Total Pages : 179 pages
Book Rating : 4.6/5 (423 download)

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Book Synopsis International Company Taxation by : Ulrich Schreiber

Download or read book International Company Taxation written by Ulrich Schreiber and published by Springer Science & Business Media. This book was released on 2013-01-30 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

Davies Principles of Tax Law

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Publisher :
ISBN 13 : 9780421858305
Total Pages : 466 pages
Book Rating : 4.8/5 (583 download)

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Book Synopsis Davies Principles of Tax Law by : David W. Williams

Download or read book Davies Principles of Tax Law written by David W. Williams and published by . This book was released on 2004 with total page 466 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this established revenue textbook makes tax law understandable by demystifying the jargon, and will be welcomed by undergraduates, teachers of tax law and practitioners needing a simple guide to the subject. It concentrates on explaining the various principles underlying the major taxes, as well as offering an insight into how tax law has developed and is applied. It covers the basic principles of income tax, corporation tax, capital gains tax, inheritance tax and VAT and analyses how each tax operates. Davies: Principles of Tax Law includes online supplements, enabling the authors to update the book with the latest legislative and case law developments. (www sweetandmaxwell.co.uk/academic) Major developments in the fifth edition include: The significant developments in EU tax law The impact on tax law of the Convention on Human Rights The major changes arising from the tax law rewrite programme - employment income (already enacted) and trading income and income from land, and savings income (in progress) The expected major rewrite of the pensions provisions Tax credits A new chapter on taxation of intellectual property; The significant developments in VAT in res

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 612 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Black Letter Outline on Corporate Taxation

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Publisher : West Academic Publishing
ISBN 13 : 9781642428933
Total Pages : 402 pages
Book Rating : 4.4/5 (289 download)

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Book Synopsis Black Letter Outline on Corporate Taxation by : Stephen Schwarz

Download or read book Black Letter Outline on Corporate Taxation written by Stephen Schwarz and published by West Academic Publishing. This book was released on 2019-08-05 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: This comprehensive and clearly written text is designed to help students recognize and understand the basic principles and issues covered in law school courses in corporate taxation at both the J.D. and LL.M. levels. It explains all the fundamental concepts and transactions affecting C and S corporations and their shareholders, and includes numerous illustrative examples, self-test questions with answers, and sample exam questions. The Ninth Edition incorporates all relevant provisions of the 2017 legislation known as the Tax Cuts and Jobs Act.

Tax Law and Digitalization: The New Frontier for Government and Business

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403534044
Total Pages : 305 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Tax Law and Digitalization: The New Frontier for Government and Business by : Jeffrey Owens

Download or read book Tax Law and Digitalization: The New Frontier for Government and Business written by Jeffrey Owens and published by Kluwer Law International B.V.. This book was released on 2021-09-15 with total page 305 pages. Available in PDF, EPUB and Kindle. Book excerpt: New technologies are changing the way that tax administrations, taxpayers and their advisers interact, leading to a reduction in the compliance cost for taxpayers, a level playing field for large and small businesses, and fewer opportunities to engage in aggressive tax practices. Although entering a new world where processes are supported by machines inevitably disrupts traditional ways of working, the contributors to this indispensable book reveal the enormous potential of ‘tax technology’ to positively transform tax compliance, clearly showing both government and business how to manage the transition from the old to the new. With detailed treatment of the technology available in the tax field, the authors describe how to secure its benefits in such ways as the following: electronic balance sheets and invoices; automated transmission to tax authorities; innovative analytics applications; blockchain in tax law processes; process mining in VAT; real-time reporting with cryptography; and meeting the challenges to taxpayers’ rights to privacy and personal data protection. The contributions draw on an international conference held under the auspices of the Digital Economy Taxation Network at the Vienna University of Economics and Business in December 2020. The perspective throughout focuses on how to achieve better tax compliance at a lower cost. For this reason, this full-scale, practical guide on how to adapt tax law to new technologies and how to apply tax tech processes in practice will be welcomed by tax practitioners, tax administrations, and academics across the entire tax community.

Federal Income Taxation

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Publisher :
ISBN 13 :
Total Pages : 52 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Federal Income Taxation by : Michael J. Graetz

Download or read book Federal Income Taxation written by Michael J. Graetz and published by . This book was released on 2002 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of Partnership Taxation

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Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Fundamentals of Partnership Taxation by : Stephen A. Lind

Download or read book Fundamentals of Partnership Taxation written by Stephen A. Lind and published by . This book was released on 2002 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Tax Transfer Pricing

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Author :
Publisher : Gruppo 24 Ore
ISBN 13 :
Total Pages : 446 pages
Book Rating : 4.2/5 (548 download)

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Book Synopsis Tax Transfer Pricing by : Andrea Musselli

Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.

Principles of Business, Marketing, and Finance

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Author :
Publisher : Goodheart-Wilcox Publisher
ISBN 13 : 9781649250261
Total Pages : 560 pages
Book Rating : 4.2/5 (52 download)

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Book Synopsis Principles of Business, Marketing, and Finance by : Robert L. Dansby

Download or read book Principles of Business, Marketing, and Finance written by Robert L. Dansby and published by Goodheart-Wilcox Publisher. This book was released on 2021-12-20 with total page 560 pages. Available in PDF, EPUB and Kindle. Book excerpt: Principles of Business, Marketing, and Finance offers pedagogical tools and hands-on activities that prepare students to become knowledgeable consumers, digital citizens, and successful employees or entrepreneurs, as they maximize their knowledge of business concepts. The basics of business, marketing, and finance―as well as personal finance and career management―are introduced in an easy-to-understand manner that helps students apply math, English Language Arts, technology, and soft skills to plan for a future career. The second edition has been updated to reflect recent changes in tax laws and procedures, and includes new coverage of workplace diversity and safety, understanding FAFSA for education and personal financial planning, and management challenges such as insider trading and legal procedures.

Business, Civil Society and the ‘New’ Politics of Corporate Tax Justice

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Author :
Publisher : Edward Elgar Publishing
ISBN 13 : 1788114973
Total Pages : 332 pages
Book Rating : 4.7/5 (881 download)

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Book Synopsis Business, Civil Society and the ‘New’ Politics of Corporate Tax Justice by : Richard Eccleston

Download or read book Business, Civil Society and the ‘New’ Politics of Corporate Tax Justice written by Richard Eccleston and published by Edward Elgar Publishing. This book was released on 2018-11-30 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the financial crisis the extent of corporate tax avoidance has attracted media headlines and the attention of political leaders the world over. This study examines the ‘new’ politics of corporate taxation and the role of civil society organisations in shaping the international tax agenda and influencing the tax practices of the world’s largest and most powerful corporations. It highlights the complex and multi-dimensional strategies used by activists to influence public opinion, formal regulation and corporate behaviour in relation to international taxation.