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Taxation Of Corporate Groups
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Book Synopsis Corporate Taxation, Group Debt Funding and Base Erosion by : Gianluigi Bizioli
Download or read book Corporate Taxation, Group Debt Funding and Base Erosion written by Gianluigi Bizioli and published by Kluwer Law International. This book was released on 2020-02-07 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.
Book Synopsis The Taxation of Corporate Groups Under Consolidation by : Antony Ting
Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by Cambridge University Press. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux
Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
Book Synopsis Introduction to Business by : Lawrence J. Gitman
Download or read book Introduction to Business written by Lawrence J. Gitman and published by . This book was released on 2023-05-19 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Taxation of Banking by : John Abrahamson
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Book Synopsis Risk and Return for Regulated Industries by : Bente Villadsen
Download or read book Risk and Return for Regulated Industries written by Bente Villadsen and published by Academic Press. This book was released on 2017-04-27 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: Risk and Return for Regulated Industries provides a much-needed, comprehensive review of how cost of capital risk arises and can be measured, how the special risks regulated industries face affect fair return, and the challenges that regulated industries are likely to face in the future. Rather than following the trend of broad industry introductions or textbook style reviews of utility finance, it covers the topics of most interest to regulators, regulated companies, regulatory lawyers, and rate-of-return analysts in all countries. Accordingly, the book also includes case studies about various countries and discussions of the lessons international regulatory procedures can offer. - Presents a unified treatment of the regulatory principles and practices used to assess the required return on capital - Addresses current practices before exploring the ways methods play out in practice, including irregularities, shortcomings, and concerns for the future - Focuses on developed economies instead of providing a comprehensive global reviews - Foreword by Stewart C. Myers
Book Synopsis Tax Law Design and Drafting, Volume 1 by : Mr.Victor Thuronyi
Download or read book Tax Law Design and Drafting, Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
Book Synopsis The Effects of Taxation on Multinational Corporations by : Martin Feldstein
Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
Book Synopsis Federal Income Taxation of Corporations Filing Consolidated Returns by : Herbert Jack Lerner
Download or read book Federal Income Taxation of Corporations Filing Consolidated Returns written by Herbert Jack Lerner and published by WCB/McGraw-Hill. This book was released on 1997 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: An invaluable tax planning guide & procedural manual that meets the demand for substantial analysis of this domain of tax law. 4 Volumes; Looseleaf; updated semi-annually.
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.
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 Tax and Corporate Governance by : Wolfgang Schön
Download or read book Tax and Corporate Governance written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2008-03-12 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: Academic research shows that well-known principal-agent and capital market problems are strongly influenced by tax considerations. Against this background, this volume is the first to present a fully-fledged overview of the interdependence of tax and corporate governance. Not only the basic political, legal and economic questions but also major topics like income measurement, shareholding structures, corporate social responsibility and tax shelter disclosure are covered.
Book Synopsis Taxation of Corporate Groups by : Miguel Correia
Download or read book Taxation of Corporate Groups written by Miguel Correia and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book proposes an interdisciplinary and comparative approach to the taxation of corporate groups. Chapter 1 analyses the core mechanical pillars of corporate income tax (CIT) systems and their impact on corporate behaviour. Chapter 2 first analyses the economic, legal and functional nature of corporate groups. Then, it examines the fundamental mechanical operation of CIT systems assuming that no tax integration solution, such as group taxation or flow-through taxation, is applicable, and assesses the merits and shortfalls of taxing corporate groups in this manner. Conversely, in chapter 3 the book analyses how corporate groups may be taxed under tax integration solutions and investigates the consequences of adopting such a stance. The study concludes, in chapter 4, by proposing a set of policy guidelines that should be considered when approaching the taxation of corporate groups.
Download or read book Corporate Tax Law written by Peter Harris and published by Cambridge University Press. This book was released on 2013-03-07 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many corporate tax systems lack structure. Focusing on structural defects and how they are addressed in practice, this comprehensive and comparative analysis of corporate tax systems uses a conceptual framework to illustrate and analyse the many difficult issues corporations pose. This framework is enhanced by the examination of a large body of legal rules and practical considerations which demonstrate how corporate tax systems work in practice. While adopting a broad comparative approach, the analysis also drills down into the detail of influential corporate tax systems in order to illustrate the major issues they face and the options available to them.
Book Synopsis Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings by : Ansgar A. Simon
Download or read book Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings written by Ansgar A. Simon and published by Kluwer Law International B.V.. This book was released on 2023-08-31 with total page 2424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.
Book Synopsis The Taxation of Corporations in Massachusetts ... by : Harry George Friedman
Download or read book The Taxation of Corporations in Massachusetts ... written by Harry George Friedman and published by . This book was released on 1907 with total page 188 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Shipowners' Limitation of Liability by : Miguel Correia
Download or read book Shipowners' Limitation of Liability written by Miguel Correia and published by Kluwer Law International B.V.. This book was released on 2013-01-06 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book refines the features of a variety of different common law and civil law systems down to a recognizable standard CIT system, identifying in the process the system’s core strengths and problems, as well as the factors that determine its impact on corporate behavior. The author offers insightful perspectives on such crucial issues as the following: corporate group members versus corporate groups as taxable entities; anti-abuse rules and developments in judicial anti-abuse doctrines; costs associated with, e.g., valuation of assets, compliance, and administration; how certain core CIT concepts are independent of tax law; efficiency, equity, and the protection of existing property rights; the firm’s reaction to behavioral control instruments; limitations on the use of losses; depreciation and amortization rules; manipulation of legal characterization; and transfer of assets and income. The work has an interdisciplinary approach drawing on the literatures of tax law, economics, corporate law, accounting, and business management. It concludes with a set of policy guidelines that should be considered when approaching the traditionally cumbersome interaction between tax systems and corporate groups. Especially valuable to the practitioner are the book’s extensive graphic design solutions illustrating the subtleties of the operation of corporate tax laws. Analyzing the taxation of corporate groups in a user-friendly form not available in any other source, this book greatly enhances the development of advanced tax planning methods that do not disrupt the economic operation of businesses. Its comprehensive conceptual framework will greatly facilitate the work of those, from practitioners to researchers, interested in developing a practical approach to corporate income taxation applicable at a global level.
