Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law

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Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087221398
Total Pages : 1093 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto

Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.

The International Tax Law Concept of Dividend

Author : Marjaana Helminen
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041183957
Total Pages : 306 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen

Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective

Author : Erwin Nijkeuter
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041140859
Total Pages : 168 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective by : Erwin Nijkeuter

Download or read book Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective written by Erwin Nijkeuter and published by Kluwer Law International B.V.. This book was released on 2012-08-01 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.

European Union Corporate Tax Law

Author : Christiana H. J. I. Panayi
Publisher : Cambridge University Press
ISBN 13 : 1108983480
Total Pages : 397 pages
Book Rating : 4.1/5 (89 download)

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Book Synopsis European Union Corporate Tax Law by : Christiana H. J. I. Panayi

Download or read book European Union Corporate Tax Law written by Christiana H. J. I. Panayi and published by Cambridge University Press. This book was released on 2021-06-17 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies, and permanent establishments. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.

Taxation of Companies on Capital Gains on Shares Under Domestic Law, EU Law and Tax Treaties

Author :
Publisher :
ISBN 13 : 9789077222133
Total Pages : pages
Book Rating : 4.2/5 (221 download)

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Book Synopsis Taxation of Companies on Capital Gains on Shares Under Domestic Law, EU Law and Tax Treaties by :

Download or read book Taxation of Companies on Capital Gains on Shares Under Domestic Law, EU Law and Tax Treaties written by and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a comprehensive study on the taxation of capital gains on shares derived by companies. The book begins by discussing the trends in the taxation of capital gains on shares under domestic law, taking into account the input from various national reports. It then considers the taxation of capital gains on shares in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of capital gains on shares and the possible impact of the EU income tax directives are examined. Next, the book discusses the taxation of capital gains on shares under tax treaties. The focus initially is on the notion of "capital gains on shares" in the OECD Model Convention and the qualification conflicts possibly arising in this respect. In addition, attention is also devoted to tax treaty aspects of company reorganizations that could trigger taxation of capital gains on shares and to tax treaty provisions regarding shares attributable to permanent establishments and non-discrimination. Finally, the application of domestic and agreement-based anti-abuse rules to transfers of shares is thoroughly analysed, with an eye also on recent rules and doctrines aimed at taxing indirect transfers. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in North America, selected European jurisdictions, Australia, China and India.

The Impact of Tax Treaties and EU Law on Group Taxation Regimes

Author : Bruno da Silva
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041169091
Total Pages : 650 pages
Book Rating : 4.0/5 (411 download)

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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 650 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.

Withholding Taxation in the EU

Author : Florian Haase
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.

EU Tax Law

Author : Marjaana Helminen
Publisher : IBFD
ISBN 13 : 9087220960
Total Pages : 453 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis EU Tax Law by : Marjaana Helminen

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.

Residence of Companies Under Tax Treaties and EC Law

Author : Guglielmo Maisto (jurist.)
Publisher : IBFD
ISBN 13 : 9087220561
Total Pages : 969 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Residence of Companies Under Tax Treaties and EC Law by : Guglielmo Maisto (jurist.)

Download or read book Residence of Companies Under Tax Treaties and EC Law written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2009 with total page 969 pages. Available in PDF, EPUB and Kindle. Book excerpt: Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.

The Meaning of "enterprise", "business" and "business Profits" Under Tax Treaties and EU Tax Law

Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087221010
Total Pages : 675 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis The Meaning of "enterprise", "business" and "business Profits" Under Tax Treaties and EU Tax Law by : Guglielmo Maisto

Download or read book The Meaning of "enterprise", "business" and "business Profits" Under Tax Treaties and EU Tax Law written by Guglielmo Maisto and published by IBFD. This book was released on 2011 with total page 675 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Meaning of "Enterprise", "Business" and "Business Profits" under Tax Treaties and EU Tax Law, comprising the proceedings and working documents of an annual seminar held in Milan in November 2010, provides an in-depth analysis of the meaning of these three essential concepts in relevant tax treaties and law. The analysis starts from an EU tax law perspective, with a particular emphasis on the European Directives. The above concepts are then considered from domestic tax law viewpoints. The book then moves to tax treaty law. Most notably, an examination of the history and interpretation of the concepts of "enterprise", "business" and "business profits" is presented, starting from the works of the League of Nations to the current OECD Model Tax Convention. Next, specific tax treaty issues are considered. In particular, the controversial issues concerning the interpretation of the notions of "enterprise" and "enterprise of a Contracting State" are discussed. Also, the concepts of "profits" and "business profits" are thoroughly reviewed. The concept of "enterprise" in the context of the non-discrimination clause laid down by Art. 24 of the OECD Model Tax Convention is then examined. Individual country surveys provide an in-depth analysis of the aforementioned concepts and issues from a national viewpoint in selected European and North American jurisdictions, as well as in Australia and Japan. The book concludes with a round-table discussion among some of the most renowned international tax scholars on the desirability to change the OECD Model Tax Convention and its Commentaries. This book is essential reading for all those dealing with issues of taxation of enterprises engaged in cross-border activities and can be considered a new cornerstone in the subject matter."--Publisher's website

International Tax Aspects of Sovereign Wealth Investors

Author : Richard Snoeij
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194339
Total Pages : 378 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Tax Aspects of Sovereign Wealth Investors by : Richard Snoeij

Download or read book International Tax Aspects of Sovereign Wealth Investors written by Richard Snoeij and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.

The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities

Author : Marjaana Helminen
Publisher : Springer
ISBN 13 : 9789041197658
Total Pages : 0 pages
Book Rating : 4.1/5 (976 download)

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Book Synopsis The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities by : Marjaana Helminen

Download or read book The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities written by Marjaana Helminen and published by Springer. This book was released on 1999-12-09 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: payments made under dividend-stripping arrangements fictitious profit distributions economic benefits in the context of transfer pricing returns on debt-equity hybrids interest payments in thin capitalisation situations and distributions following liquidation The analysis of each transaction refers to international tax law, including tax treaties, European tax law and the domestic tax law of Finland, Germany, Sweden and the United States. The comprehensive coverage and practical nature of The Dividend Concept in International Tax Law make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

The Integration of Corporate and Personal Taxes in Europe

Author : Michael P. Devereux
Publisher : The Committee
ISBN 13 :
Total Pages : 40 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis The Integration of Corporate and Personal Taxes in Europe by : Michael P. Devereux

Download or read book The Integration of Corporate and Personal Taxes in Europe written by Michael P. Devereux and published by The Committee. This book was released on 1997 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: The paper describes in some detail the imputation systems in France, Germany, Italy and the United Kingdom, paying particular attention to the minimum tax. It also briefly addresses a number of economic issues; it examines the likely impact of the minimum tax on the investment and financing decisions of companies, and outlines how the impact of the imputation system depends on the minimum tax; and it also briefly raises the issue of alternative forms of taxation of corporate source income.

Traditional and Alternative Routes to European Tax Integration

Author : Dennis Weber
Publisher : IBFD
ISBN 13 : 9087220839
Total Pages : 377 pages
Book Rating : 4.0/5 (872 download)

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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).

Explanation of proposed protocol to the income tax treaty between the United States and Denmark

Author :
Publisher : DIANE Publishing
ISBN 13 : 9781422321157
Total Pages : 94 pages
Book Rating : 4.3/5 (211 download)

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Book Synopsis Explanation of proposed protocol to the income tax treaty between the United States and Denmark by :

Download or read book Explanation of proposed protocol to the income tax treaty between the United States and Denmark written by and published by DIANE Publishing. This book was released on 2007 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Effect of Directives Within the Area of Direct Taxation on the Interpretation and Application of Tax Treaties

Author : Mees Vergouwen
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403509171
Total Pages : 351 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis The Effect of Directives Within the Area of Direct Taxation on the Interpretation and Application of Tax Treaties by : Mees Vergouwen

Download or read book The Effect of Directives Within the Area of Direct Taxation on the Interpretation and Application of Tax Treaties written by Mees Vergouwen and published by Kluwer Law International B.V.. This book was released on 2023-07-14 with total page 351 pages. Available in PDF, EPUB and Kindle. Book excerpt: In recognition of the considerable attention in recent years given to the effect of EU directives on tax treaties, this important book for the first time brings a combined public international law and European Union law perspective to bear on certain directives – primarily the Parent-Subsidiary Directive, the Merger Directive, the Interest and Royalty Directive, and the Anti-Tax Avoidance Directives – and their interaction with tax treaties concluded by EU Member States. In this area of direct international taxation, the author examines the effect of tax treaties on both the interpretation and application of directives in depth. In clarifying how directives can affect or are allowed to affect, tax treaties, the book provides detailed analyses of such aspects as the following: status of directives under public international law, including relevant provisions of the Vienna Convention on the Law of Treaties and the OECD Model Tax Treaty; whether national law aimed at implementing a directive may be able to override a tax treaty or may be overridden by such a tax treaty; whether the lex posterior and lex specialis conflict rules under public international law are applicable to conflicts between directives and tax treaties; the role of directives under the interpretative provision of the Vienna Convention on the Law of Treaties, the OECD Model Tax Treaty and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting; legal basis and application of the duty of consistent interpretation to tax treaties; and scope of the primacy of directives with respect to tax treaties. The book offers insightful and well-informed recommendations aimed at aligning the ‘allowed’ effect under public international law and the ‘required’ effect under the laws of the European Union of the directives on tax treaties, with a view to ensuring that directives affect tax treaties in such a way that tax treaties cannot prevent achievement of the result of a directive. The analysis is based primarily on legal doctrines, literature, and case law of the CJEU, ICJ, and arbitral tribunals. As a highly informative and closely reasoned guide that offers clear perspectives on resolving any conflict that may arise between a directive and a tax treaty, this book will be of inestimable value for tax practitioners and advisers, judges, policymakers, tax authorities, and academics whose work involves tax treaties concluded by EU Member States.

The Netherlands in International Tax Planning

Author : Johann Müller (podatki)
Publisher : IBFD
ISBN 13 : 9087220243
Total Pages : 417 pages
Book Rating : 4.0/5 (872 download)

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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.