The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403543078
Total Pages : 330 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention by : David Orzechowski-Zölzer

Download or read book The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention written by David Orzechowski-Zölzer and published by Kluwer Law International B.V.. This book was released on 2024-05-21 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.

TAXATION OF FEES FOR TECHNICAL SERVICES ON THE BASIS OF ARTICLE 12A UN MODEL CONVENTION.

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Publisher :
ISBN 13 : 9789403542973
Total Pages : 0 pages
Book Rating : 4.5/5 (429 download)

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Book Synopsis TAXATION OF FEES FOR TECHNICAL SERVICES ON THE BASIS OF ARTICLE 12A UN MODEL CONVENTION. by : DAVID. ORZECHOWSKI-ZOLZER

Download or read book TAXATION OF FEES FOR TECHNICAL SERVICES ON THE BASIS OF ARTICLE 12A UN MODEL CONVENTION. written by DAVID. ORZECHOWSKI-ZOLZER and published by . This book was released on 2024 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Special Features of the UN Model Convention

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Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410401
Total Pages : 582 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Special Features of the UN Model Convention by : Anna Binder

Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 582 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.

The U.N. Model's New Fees for Technical Services Provision

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Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (126 download)

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Book Synopsis The U.N. Model's New Fees for Technical Services Provision by : T. Falcão

Download or read book The U.N. Model's New Fees for Technical Services Provision written by T. Falcão and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the author examines the newly introduced article 12A of the U.N. model tax treaty, which specifically addresses fees for technical services, discussing how the article functions within the model, how it responds to concerns about base erosion and profit shifting, and how it fits into today's international tax environment.

Special Features of the UN Model Convention

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Publisher : Linde Verlag GmbH
ISBN 13 : 3709410398
Total Pages : 664 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Special Features of the UN Model Convention by : Anna Binder

Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 664 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.

Article 12B UN Model Convention 2021

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Publisher : Kluwer Law International B.V.
ISBN 13 : 940352488X
Total Pages : 551 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Article 12B UN Model Convention 2021 by : Christian Knotzer

Download or read book Article 12B UN Model Convention 2021 written by Christian Knotzer and published by Kluwer Law International B.V.. This book was released on 2024-07-15 with total page 551 pages. Available in PDF, EPUB and Kindle. Book excerpt: This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.

Research Handbook on International Taxation

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Publisher : Edward Elgar Publishing
ISBN 13 : 1788975375
Total Pages : 416 pages
Book Rating : 4.7/5 (889 download)

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Book Synopsis Research Handbook on International Taxation by : Yariv Brauner

Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.

International Taxation of Income from Services under Double Taxation Conventions

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041195955
Total Pages : 544 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Taxation of Income from Services under Double Taxation Conventions by : Marta Castelon

Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 544 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

Withholding Taxation in the EU

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Author :
Publisher : Edward Elgar Publishing
ISBN 13 : 1035312670
Total Pages : 275 pages
Book Rating : 4.0/5 (353 download)

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Book Synopsis Withholding Taxation in the EU by : Florian Haase

Download or read book Withholding Taxation in the EU written by Florian Haase and published by Edward Elgar Publishing. This book was released on 2023-12-11 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: Florian Haase presents a comprehensive overview of the general mechanisms by which taxation is withheld in Europe and explores their practical implications. He expertly navigates the complexities of international tax law and provides a rigorous examination of the challenges currently facing this area of legislation, including tax evasion and avoidance, double taxation, and tax treaties.

Taxation of Technical Services Under the New Article 12A of the UN Model - Improved Taxation Or a Step in the Wrong Direction?.

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Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (126 download)

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Book Synopsis Taxation of Technical Services Under the New Article 12A of the UN Model - Improved Taxation Or a Step in the Wrong Direction?. by : F. Sixdorf

Download or read book Taxation of Technical Services Under the New Article 12A of the UN Model - Improved Taxation Or a Step in the Wrong Direction?. written by F. Sixdorf and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors examine the new article 12A of the UN Model (2017), which addresses technical services. The goals of the UN Model, as well as the objectives pursued by the UN Committee with the introduction of this new provision are presented, followed by an analysis of whether the new article meets these objectives.

Klaus Vogel on Double Taxation Conventions

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403512849
Total Pages : 3112 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Klaus Vogel on Double Taxation Conventions by : Ekkehart Reimert

Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University

How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country

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Author :
Publisher : International Monetary Fund
ISBN 13 : 1513577018
Total Pages : 27 pages
Book Rating : 4.5/5 (135 download)

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Book Synopsis How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country by : Kiyoshi Nakayama

Download or read book How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country written by Kiyoshi Nakayama and published by International Monetary Fund. This book was released on 2021-05-04 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.

Tax Cooperation in an Unjust World

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Publisher : Oxford University Press
ISBN 13 : 0192664859
Total Pages : 209 pages
Book Rating : 4.1/5 (926 download)

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Book Synopsis Tax Cooperation in an Unjust World by : Allison Christians

Download or read book Tax Cooperation in an Unjust World written by Allison Christians and published by Oxford University Press. This book was released on 2021-11-29 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: The way that nation states design their tax systems impacts the sharing of resources and wealth within and across societies. To date, wealthy countries have made tax policy design and coordination choices which allow them to claim more than they are justifiably entitled to from the global economy. In Tax Cooperation in an Unjust World, Allison Christians and Laurens van Apeldoorn show how this presently accepted reality both facilitates and feeds off continued human suffering, and therefore violates conceptions of international distributive justice. They examine two principles that govern tax cooperation across states, and explain how the current international tax order impedes their realization. They then show how states could work toward fulfilling the principles and building a fairer international tax system via incremental yet effective adaptation of key international tax norms and rules.

Tax, Inequality, and Human Rights

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Publisher : Oxford University Press
ISBN 13 : 0190882255
Total Pages : 496 pages
Book Rating : 4.1/5 (98 download)

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Book Synopsis Tax, Inequality, and Human Rights by : Philip G. Alston

Download or read book Tax, Inequality, and Human Rights written by Philip G. Alston and published by Oxford University Press. This book was released on 2019-04-11 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: For the first time, Human Rights and Tax in an Unequal World brings together works by human rights and tax law experts, to illustrate the linkages between the two fields and to reveal their mutual relevance in tackling economic, social, and political inequalities. Against the backdrop of systemic corporate tax avoidance, the widespread use of tax havens, persistent pressures to embrace austerity policies, and growing gaps between the rich and poor, this book encourages readers to understand fiscal policy as human rights policy, with profound consequences for the wellbeing of citizens around the world. The essays collected examine where the foundational principles of tax law and human rights law intersect and diverge; discuss the cross-border nature and human rights impacts of abusive practices like tax avoidance and evasion; question the role of states in bringing transparency and accountability to tax policies and practices; highlight the responsibility of private sector actors for the consequences of tax laws; and critically evaluate certain domestic tax rules through the lens of equality and non-discrimination. The contributing scholars and practitioners explore how an international human rights framework can anchor debates around international tax reform and domestic fiscal consolidation in existing state obligations. They address what human rights law requires of state tax policies, and what a state's tax laws and loopholes mean for the enjoyment of human rights within and outside its borders. Ultimately, tax and human rights both turn on the relationship between the individual and the state, and thus both fields face crises as the social contract frays and populist, illiberal regimes are on the rise.

CA/CMA Final Direct Tax Question Bank for Nov/Dec 2023

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Author :
Publisher : Saket Ghiria Classes
ISBN 13 :
Total Pages : 482 pages
Book Rating : 4./5 ( download)

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Book Synopsis CA/CMA Final Direct Tax Question Bank for Nov/Dec 2023 by : CA. Saket Ghiria

Download or read book CA/CMA Final Direct Tax Question Bank for Nov/Dec 2023 written by CA. Saket Ghiria and published by Saket Ghiria Classes. This book was released on 2023-09-30 with total page 482 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Comprehensive Question Bank for CA/CMA Final Direct Tax for Nov/Dec 2023 Exams. Major Features a) Contains over 650 questions. b) Questions are non-repetitive in nature and covers a wide variety of concepts. c) One need through knowledge of the syllabus for attempting the questions. d) As far as possible, accuracy is ensured both in calculations as well as in provisions. ❤ Our YouTube Channel - https://www.youtube.com/@saketghiria ❤ Our Telegram Channel - https://t.me/sgccafinal ❤ Our Website - https://saketghiria.com ❤ Our Instagram link - https://www.instagram.com/saketghiria_classes/

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint Inclusive Framework on BEPS

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Publisher : OECD Publishing
ISBN 13 : 9264353844
Total Pages : 250 pages
Book Rating : 4.2/5 (643 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint Inclusive Framework on BEPS by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2020-10-14 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. This report explores options and issues in connection with the design of a global minimum tax that would address remaining BEPS issues.

Principles of International Taxation

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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.