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Taxation Convention With Luxembourg
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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 Investment Fund Taxation by : Werner Haslehner
Download or read book Investment Fund Taxation written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2017-04-24 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.
Book Synopsis Time and Tax: Issues in International, EU, and Constitutional Law by : Werner Haslehner
Download or read book Time and Tax: Issues in International, EU, and Constitutional Law written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 434 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.
Book Synopsis Luxembourg in International Tax by : Marc Schmitz
Download or read book Luxembourg in International Tax written by Marc Schmitz and published by . This book was released on 2015 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt: Luxembourg in International Tax' takes an in-depth look at corporate taxation in Luxembourg and the tax issues that may be of interest in an international environment. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear explanation of corporate tax in Luxembourg, it is also of interest to locally based practitioners. The first edition rapidly became a standard reference work in Luxembourg tax literature, and its reputation was maintained through the second edition, which continued being referred to and selling long after the date of issue. 0This new edition of the book is updated to incorporate tax developments on the national level up to January 2015, including the latest changes on the exchange of information, advance tax clearances and the codification of the arm’s length standard. It also covers Luxembourg’s intellectual property box regime, private wealth management companies and other investment entities, and the taxation of financing activities in Luxembourg. Furthermore, it contains a new chapter on tax treaties, which provides insight into the particularities of Luxembourg’s treaty network and its interaction with domestic law. 0The book provides a vast amount of up-to-date information combined with an in-depth analysis of business taxation in Luxembourg. It is a valuable guide for international tax experts wishing to gain a better understanding of corporate tax in Luxembourg as well as for locally based practitioners. With numerous examples given in each chapter, it will also be of interest to students.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2017 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Book Synopsis Taxation Convention with Luxembourg by : United States. Congress. Senate. Committee on Foreign Relations
Download or read book Taxation Convention with Luxembourg written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1997 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. Joint Committee on Internal Revenue Taxation Publisher : ISBN 13 : Total Pages :1510 pages Book Rating :4.3/5 (91 download)
Book Synopsis Income tax conventions by : United States. Congress. Joint Committee on Internal Revenue Taxation
Download or read book Income tax conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1510 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Treaty Interpretation by : Michael Lang
Download or read book Tax Treaty Interpretation written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2001-12-19 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.
Book Synopsis Double Taxation, Taxes on Income and Property by : Norway
Download or read book Double Taxation, Taxes on Income and Property written by Norway and published by . This book was released on 1982 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Double Taxation Within the European Union by : Alexander Rust
Download or read book Double Taxation Within the European Union written by Alexander Rust and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the conclusion of tax treaties and despite the enactment of several directives, double taxation continues to occur within the EU, causing severe obstacles for cross-border trade, for the provision of services and capital, and for the free movement of persons. This book collects the expert analysis and recommendations on the following issues: the reasons for the existence (and persistence) of juridical and economic double taxation; double burdens in criminal law; constitutional limits for double taxation; the Lisbon Treaty's abolition of Article 293 EC, which had required Member States to conclude tax treaties in order to abolish double taxation; whether double taxation can be avoided by the application of the four freedoms; prospects for an EU-wide multilateral tax treaty; the proposed Common Consolidated Corporate Tax Base; and use of arbitration clauses in tax treaties.
Book Synopsis Employment Law Review by : Erika C Collins
Download or read book Employment Law Review written by Erika C Collins and published by Law Business Research Ltd.. This book was released on 2017-04-07 with total page 1263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK
Book Synopsis Switzerland in International Tax Law by : Xavier Oberson
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Book Synopsis Luxembourg in International Tax Planning by : Philip J. Warner
Download or read book Luxembourg in International Tax Planning written by Philip J. Warner and published by IBFD. This book was released on 2004 with total page 588 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning
Book Synopsis Model Tax Convention on Income and on Capital 2017 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2017 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Draft Double Taxation Convention on Income and Capital 1963 by :
Download or read book Draft Double Taxation Convention on Income and Capital 1963 written by and published by . This book was released on 1963 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1963 report presents the articles on the avoidance of double taxation on income and capital, as agreed upon by the Fiscal Committee. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. This draft aims to inspire further conventions on the elimination of double taxation, a threat to trade and migration. The report includes commentaries on the articles, progress on the elimination of double taxation, and possible future developments.
Book Synopsis Foreign Tax and Trade Briefs by : Walter H. Diamond
Download or read book Foreign Tax and Trade Briefs written by Walter H. Diamond and published by . This book was released on 1951 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
