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Tax Arbitrage In The Netherlands
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Download or read book Tax Arbitrage written by Nigel Feetham and published by Spiramus Press Ltd. This book was released on 2011 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice.
Book Synopsis Tax by Design for the Netherlands by : Sijbren Cnossen
Download or read book Tax by Design for the Netherlands written by Sijbren Cnossen and published by Oxford University Press. This book was released on 2022 with total page 450 pages. Available in PDF, EPUB and Kindle. Book excerpt: "This book is the product of the first Cnossen Forum-Tax by design for the Netherlands that was held on 23-24 May 2019."--Page v.
Book Synopsis The Netherlands in International Tax Planning by : Johann Müller (podatki)
Download or read book The Netherlands in International Tax Planning written by Johann Müller (podatki) and published by IBFD. This book was released on 2007 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
Book Synopsis Double non-taxation and the use of hybrid entities by : Leopoldo Parada
Download or read book Double non-taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
Book Synopsis Offshore Finance and Global Governance by : William Vlcek
Download or read book Offshore Finance and Global Governance written by William Vlcek and published by Springer. This book was released on 2016-11-02 with total page 190 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts. /div
Book Synopsis Irish Income Tax 2022 by : Tom Maguire
Download or read book Irish Income Tax 2022 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2022-08-26 with total page 2963 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The Bible of Irish income tax ...", Irish Independent, 28 January 2018. This annual publication on Irish income tax is the long-established leading authority in the area. This tax essential, formerly known as Judge, is the leading income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It provides a complete analysis of the principles and practice of income tax in the Republic of Ireland. It also provides an examination of recent key decisions by the courts both in Ireland and in the UK, as well as by the Tax Appeal Commissioners. This new edition is updated to Finance Act 2021.
Book Synopsis Irish Income Tax 2023 by : Tom Maguire
Download or read book Irish Income Tax 2023 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2023-08-11 with total page 3079 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The Bible of Irish income tax ...", Irish Independent, 28 January 2018. This tax essential, formerly known as Judge, is the leading income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It provides a complete analysis of the principles and practice of income tax in Ireland. It also provides an examination of recent key decisions by the courts both in Ireland and in the UK, as well as by the Tax Appeal Commissioners. This new edition is updated to Finance Act 2022. This title is included in Bloomsbury Professional's Irish Tax online service.
Book Synopsis Irish Income Tax 2021 by : Tom Maguire
Download or read book Irish Income Tax 2021 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 2870 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'The Bible of Irish income tax...' - Irish Independent, 28 January 2018 Tom Maguire's annual publication on Irish income tax is the long-established leading authority in the area. This immensely popular tax essential is the number one income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It endeavours to provide a complete analysis of the principles and practice of income tax in the Republic of Ireland. This new edition is based on the Finance Act 2020. It also provides an examination of recent key decisions by the courts both here and in the UK, as well as by the Tax Appeal Commissioners. The 2021 edition deals with changes in relation to pandemic unemployment payments, the dependent relative tax credit and the mobility allowance. In particular the new edition examines the impact of the Covid Restrictions Support Scheme, which is available to eligible businesses who carry on an activity that is impacted by the Covid-19 Restrictions.
Book Synopsis Hedonic valuation of Dutch wetlands. by :
Download or read book Hedonic valuation of Dutch wetlands. written by and published by Rozenberg Publishers. This book was released on 2001 with total page 182 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Introduction to Dutch Law by : Larissa van den Herik
Download or read book Introduction to Dutch Law written by Larissa van den Herik and published by Kluwer Law International B.V.. This book was released on 2022-01-27 with total page 1049 pages. Available in PDF, EPUB and Kindle. Book excerpt: A standard legal resource since its first edition in 1978, this matchless book has proven itself the ideal overview of Dutch law for foreign lawyers. This Sixth Edition fully updates its systematic description of the legal sources, institutions, and concepts in all major fields of law. Recent developments covered include the progressive implementation of standards set by international conventions, the reorganization of the judiciary, the statute on environmental law, and the (re)codification of private international law. The continuing influence of European law is evident in many fields, perhaps most notably in family law. The various chapters are written by experts – scholars and lawyers – in particular fields, and provide an authoritative overview of each field. The historical sources of Dutch law are discussed, as well as Dutch legal culture, legal philosophy, judicial organization, legal education, and the legal profession. These chapters are followed by introductions to essential issues of private and public law and labour law. The last chapter examines financial law. The only resource of its kind available, this book is unmatched as a thorough guide to further research. It offers practitioners, particularly foreign lawyers, a quick and reliable way into any area of Dutch law that they may be required to research. It will also be of great value to comparatists (especially those studying the influence of European law on national legal systems), scholars, and students. Like previous editions, the Sixth Edition has been prepared under the auspices of the Netherlands Comparative Law Association.
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Author :Bert Alink Publisher :Institut für Finanz- und Steuerrecht, Universität Osnabrück ISBN 13 :3981489470 Total Pages :586 pages Book Rating :4.9/5 (814 download)
Book Synopsis Taxing German-Dutch Cross-Border Activities by : Bert Alink
Download or read book Taxing German-Dutch Cross-Border Activities written by Bert Alink and published by Institut für Finanz- und Steuerrecht, Universität Osnabrück. This book was released on 2015-02-04 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.
Book Synopsis The Impact of Tax Treaties and EU Law on Group Taxation Regimes by : Bruno da Silva
Download or read book The Impact of Tax Treaties and EU Law on Group Taxation Regimes written by Bruno da Silva and published by Kluwer Law International B.V.. This book was released on 2016-07-11 with total page 789 pages. Available in PDF, EPUB and Kindle. Book excerpt: Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.
Book Synopsis Traditional and Alternative Routes to European Tax Integration by : Dennis Weber
Download or read book Traditional and Alternative Routes to European Tax Integration written by Dennis Weber and published by IBFD. This book was released on 2010 with total page 377 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax integration within the European Union can take place in many ways. In this book, various instruments which the Member States and the European Union have available to attain tax integration are discussed and their mutual relationship is studied. The book includes a general report drafted by the editor and is divided into seven parts focusing on (i) Sources of EU law for integration in direct and indirect taxation, (ii) Soft law: Solution or disillusion? Limits?, (iii) Infringement procedures: Another way to move things further?, (iv) Comitology, (v) Relationship between primary and secondary EU law, (vi) VAT Directive tested against primary law, and (vii) Direct tax directives tested against primary law. The book is the outcome of the fourth annual conference of the GREIT (Group for Research on European and International Taxation).
Book Synopsis Double (Non-)Taxation and EU Law by : Christoph Marchgraber
Download or read book Double (Non-)Taxation and EU Law written by Christoph Marchgraber and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 460 pages. Available in PDF, EPUB and Kindle. Book excerpt: Everywhere,new tax rules are under development to engage with the ever-increasing complexity and sophistication of aggressive tax planning and to reverse the tax base erosion it leads to. The most prominent initiative in this context is the Base Erosion and Profit Shifting (BEPS) project of the OECD. Although double non-taxation is among the main issues the BEPS project intends to address, this book shows that this phenomenon has not yet been fully understood. Focusing on the fundamental freedoms and the State aid rules of the EU, this book thoroughly explains the nature of double non-taxation from an EU law perspective, its relation to double taxation, and the impact of EU law on these phenomena. Among the issues dealt with in the course of the analysis are the following: – locating the gaps and inconsistencies among domestic tax systems exploited by taxpayers; – hybrid mismatch arrangements as a prime example of double non-taxation; – political efforts undertaken within the EU in order to address double taxation and double non-taxation; – double non-taxation in the European VAT system; – the convergence of the fundamental freedoms and the State aid rules; – the ECJ’s dilemma with regard to juridical double taxation; – the deviating approach with regard to economic double taxation; – the potential impact of the ECJ’s case law on the EU law compatibility of double non-taxation. The tax jurisprudence of the ECJ is referred to and comprehensively analysed throughout this whole book. A final chapter provides an outlook on possible developments in the future. By providing the first in-depth analysis of EU law’s impact on double non-taxation – and the double taxation relief standards with which it is intimately related – this book takes a giant step towards greater legal certainty in this challenging area of tax law. It will quickly take its place as a major practical analysis which benefits tax authorities, scholars, and tax practitioners across Europe and even beyond.
Download or read book EU Tax Law written by Marjaana Helminen and published by IBFD. This book was released on 2011 with total page 453 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book deals with all the EC law norms that are relevant from the perspective of direct taxes. It explains how these norms are, and should be, interpreted and how they affect national tax laws and the tax treatment in EU Member States. It begins by giving a comprehensive overview of the basic principles and concepts of EC tax law and all relevant articles of the EC Treaty, analysing them in the light of direct tax case law. A discussion follows covering all relevant EC directives and recommendations and other soft law material on direct taxes. Reference is made to all relevant judgments of the EC Court on direct taxes. The book includes a chapter on the tax treatment of the different EU entity forms and the future of corporate taxation, with a separate chapter dedicated to the EC law issues related to transfer pricing and to the EC law norms on administrative assistance in tax matters.
Book Synopsis Taxation in a Global Economy by : Andreas Haufler
Download or read book Taxation in a Global Economy written by Andreas Haufler and published by Cambridge University Press. This book was released on 2001-08-23 with total page 354 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increasing international mobility of capital, firms and consumers has begun to constrain tax policies in most OECD countries, playing a major role in reforming national tax systems. Haufler uses the theory of international taxation to consider the fundamental forces underlying this process, covering both factor and commodity taxes, as well as their interaction. Topics include a variety of different international tax avoidance strategies - capital flight, profit shifting in multinational firms, and cross-border shopping by consumers. Situations in which tax competition creates conflicting interests between countries are given particular consideration. Haufler addresses the complex issue of coordination in different areas of tax policy, with special emphasis on regional tax harmonization in the European Union. Also included is a detailed introduction to recent theoretical literature.
