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Resolution Of Tax Treaty Conflicts By Arbitration
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Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker
Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Book Synopsis Tax Treaty Arbitration by : Michael Lang
Download or read book Tax Treaty Arbitration written by Michael Lang and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an overview of the effectiveness of tax treaty arbitration and the approach towards recent legislative changes in 36 countries across the globe.
Book Synopsis Dispute Resolution Under Tax Treaties by : Zvi Daniel Altman
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Book Synopsis Schwarz on Tax Treaties by : Jonathan Schwarz
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Book Synopsis Resolution of Tax Treaty Conflicts by Arbitration by :
Download or read book Resolution of Tax Treaty Conflicts by Arbitration written by and published by Springer. This book was released on 1994-11-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proceedings of a seminar held in Florence, Italy, in 1993 during the 47th congress of the International Fiscal Association.
Book Synopsis Flexible Multi-tiers Dispute Resolution in International Tax Disputes by : Pasquale Pistone
Download or read book Flexible Multi-tiers Dispute Resolution in International Tax Disputes written by Pasquale Pistone and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Prospects in International Investment Law and Policy by : Roberto Echandi
Download or read book Prospects in International Investment Law and Policy written by Roberto Echandi and published by Cambridge University Press. This book was released on 2013-04-18 with total page 495 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addresses the most central debates in contemporary investment law and policy.
Book Synopsis A Guide to the Anti-Tax Avoidance Directive by : Werner Haslehner
Download or read book A Guide to the Anti-Tax Avoidance Directive written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2020-06-26 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.
Book Synopsis International Arbitration in Tax Matters by : Michael Lang
Download or read book International Arbitration in Tax Matters written by Michael Lang and published by . This book was released on 2015 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Handbook of Dispute Resolution by : Michael L. Moffitt
Download or read book The Handbook of Dispute Resolution written by Michael L. Moffitt and published by John Wiley & Sons. This book was released on 2012-06-28 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume is an essential, cutting-edge reference for all practitioners, students, and teachers in the field of dispute resolution. Each chapter was written specifically for this collection and has never before been published. The contributors--drawn from a wide range of academic disciplines--contains many of the most prominent names in dispute resolution today, including Frank E. A. Sander, Carrie Menkel-Meadow, Bruce Patton, Lawrence Susskind, Ethan Katsh, Deborah Kolb, and Max Bazerman. The Handbook of Dispute Resolution contains the most current thinking about dispute resolution. It synthesizes more than thirty years of research into cogent, practitioner-focused chapters that assume no previous background in the field. At the same time, the book offers path-breaking research and theory that will interest those who have been immersed in the study or practice of dispute resolution for years. The Handbook also offers insights on how to understand disputants. It explores how personality factors, emotions, concerns about identity, relationship dynamics, and perceptions contribute to the escalation of disputes. The volume also explains some of the lessons available from viewing disputes through the lens of gender and cultural differences.
Book Synopsis Dispute Resolution by : Stephen B. Goldberg
Download or read book Dispute Resolution written by Stephen B. Goldberg and published by Aspen Publishers. This book was released on 1995 with total page 148 pages. Available in PDF, EPUB and Kindle. Book excerpt: This best-selling casebook has already helped thousands of students master the fundamentals of dispute resolution. With its broad, comprehensive coverage & direct, accessible approach, DISPUTE RESOLUTION: Negotiation, Mediation, & Other Processes, Third Edition, is ideally suited for use in the traditional ADR survey course. For each of the three main branches of alternative dispute resolution negotiation, mediation, & arbitration the authors: critically examine the branch & its "hybrid" offshoots present careful explanations giving students a solid foundation for future practice describe & analyze applications & their appropriate environments present hypothetical exercises that allow students to evaluate the technique Scrupulously updated for its Third Edition, DISPUTE RESOLUTION: Negotiation, Mediation, & Other Processes now offers: new social science findings on the effectiveness of mediation new coverage of mediation regulation a new section on mediation in the context of cultural differences more detailed treatment of ethics issue timely material on malpractice liability & non-union arbitration a new appendix providing a Research Guide to ADR new problems of the same high quality the book has always represented For the latest coverage of the most important issues in ADR, you can depend on Goldberg, Sander, & Rogers & their proven-effective casebook, which is accompanied by a solid Teacher's Manual.
Book Synopsis Public Actors in International Investment Law by : Catharine Titi
Download or read book Public Actors in International Investment Law written by Catharine Titi and published by Springer Nature. This book was released on 2021 with total page 205 pages. Available in PDF, EPUB and Kindle. Book excerpt: This open access book focuses on public actors with a role in the settlement of investment disputes. Traditional studies on actors in international investment law have tended to concentrate on arbitrators, claimant investors and respondent states. Yet this focus on the "principal" players in investment dispute settlement has allowed a number of other seminal actors to be neglected. This book seeks to redress this imbalance by turning the spotlight on the latter. From the investor's home state to domestic courts, from sub-national governments to international organisations, and from political risk insurance agencies to legal defence teams in national ministries, the book critically reviews these overlooked public actors in international investment law.
Book Synopsis Investment Treaty Arbitration by : Kaj Hobér
Download or read book Investment Treaty Arbitration written by Kaj Hobér and published by . This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Investment Treaty Arbitration is an excellent teaching tool for lecturers and readers of international investment arbitration. This casebook includes over forty exercises based on real-life disputes, helping readers evaluate and analyze all aspects of the topic. Intended to set out a basis for discussion in seminars, the material has been developed by the eminent practitioner and academic Kaj Hobér, using a teaching structure proven to be successful. Key features include: ? extensive examples of cases alongside seminar exercises and mini mock arbitrations to help students put their knowledge into practice material built on the problem-based learning method, using fact patterns and allowing for in-depth discussion and a confident understanding of complex arbitration cases? exercises including questions to answer, problems to solve and group exercises, alongside excerpts of the relevant cases for annotation and analysis. The most wide-ranging textbook in the area, covering both substantive investment law and arbitration, this will become the key casebook for Master?'s level courses or other advanced courses in international arbitration. It will also serve as a supplementary text for those studying investment law more broadly.
Book Synopsis Handbook on the Peaceful Settlement of Disputes Between States by : United Nations. Codification Division
Download or read book Handbook on the Peaceful Settlement of Disputes Between States written by United Nations. Codification Division and published by New York : United Nations. This book was released on 1992 with total page 268 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi
Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Book Synopsis Arbitration Under International Investment Agreements by : Katia Yannaca-Small
Download or read book Arbitration Under International Investment Agreements written by Katia Yannaca-Small and published by . This book was released on 2010 with total page 790 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration Under International Investment Agreements: A Guide to the Key Issues provides a comprehensive analysis of the main issues that arise in investor-state arbitration. The contributing authors take the reader through the intricacies of this procedure before analyzing the main jurisdictional and substantive issues that confront arbitrators. The book concludes with a reflection on the role of precedent in investment arbitration. A diverse group of renowned experts in the field provide comprehensive coverage, making Arbitration Under International Investment Agreements a valuable resource for anyone working in or studying this field of law.
