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Tenth Meeting Of The Ad Hoc Group Of Experts On International Cooperation In Tax Matters
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Book Synopsis Dispute Resolution Under Tax Treaties by : Zvi Daniel Altman
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Book Synopsis Mutual Assistance for the Recovery of Tax Claims by : Maria Amparo Grau Ruiz
Download or read book Mutual Assistance for the Recovery of Tax Claims written by Maria Amparo Grau Ruiz and published by Kluwer Law International B.V.. This book was released on 2003-01-14 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential powers and necessary limits of the mutual assistance function at the national administrative level. Includes recommendations for the strengthening and effectiveness of mutual assistance procedures, considers the growing role of multilateral treaties, and envisions the possibility of an international fiscal court.
Author :United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters Publisher : ISBN 13 : Total Pages :132 pages Book Rating :4.3/5 (91 download)
Book Synopsis International Cooperation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters
Download or read book International Cooperation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by . This book was released on 1998 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt: Report of the Ad Hoc Group of Experts on International Cooperation in Tax Matters on the work of its eighth meeting which was held from 15 to 19 December 1997 in Geneva, including selected papers presented at the meeting.
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
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 773 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.
Book Synopsis Tax Evasion and the Law by : Sam Bourton
Download or read book Tax Evasion and the Law written by Sam Bourton and published by Taylor & Francis. This book was released on 2024-06-18 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a critical and contemporary evaluation of the laws and enforcement policies pertaining to tax evasion in the United Kingdom (UK) and United States (US). Since the inception of taxes, revenue collection authorities around the world have attempted to address the seemingly perennial problem of individuals evading their tax liabilities. The financial crisis has shone a new light on the issue with an increased interest in using the criminal justice system as a means of addressing it in the UK. In sharp contrast to the UK, the US has a strong record of prosecuting crimes of tax evasion, whether committed by individuals or professional corporate facilitators. Providing an evaluation of the UK’s tax evasion laws and enforcement policy, through a comparative approach, this work highlights insights provided by the US experience. In so doing, the book explores the interconnections between tax evasion and money laundering, identifying best practices, omissions, and areas for reform. The work will be a valuable resource for researchers, academics, and policy-makers working in the areas of financial crime, financial law, accountancy and criminal justice.
Book Synopsis Official Records of the ... Session of the General Assembly by :
Download or read book Official Records of the ... Session of the General Assembly written by and published by . This book was released on 1999 with total page 1498 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Transfer Pricing of Intangibles by : Michelle Markham
Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
Book Synopsis The Concept of Permanent Establishment in the Insurance Business by : Daniele Frescurato
Download or read book The Concept of Permanent Establishment in the Insurance Business written by Daniele Frescurato and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Book Synopsis International Financial Services Sectors in Small Vulnerable Economies by : Andreas Antoniou
Download or read book International Financial Services Sectors in Small Vulnerable Economies written by Andreas Antoniou and published by Commonwealth Secretariat. This book was released on 2004 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: The publication is a collection of papers on current trends in financial regulation and supervision and particularly their impact on small vulnerable economies. The papers examine the following areas: trends in international financial regulation and supervision; political strategies for protecting Small States interests in global regulatory reform; sustainable capital markets and regional integration (the case of the Eastern Caribbean Currency Union) and international cooperation on taxation. The publication should prove useful to policy-makers in these countries as well as academics."
Book Synopsis Handbook of Research on Public Finance in Europe and the MENA Region by : Erdo?du, M. Mustafa
Download or read book Handbook of Research on Public Finance in Europe and the MENA Region written by Erdo?du, M. Mustafa and published by IGI Global. This book was released on 2016-05-03 with total page 652 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the 1970s, globalization has created an economic environment of interdependency between nations. Now, many countries in European and the MENA (Middle East and Northern Africa) regions must grapple with the need to increase public revenue while maneuvering through a global “race-to-the-bottom” tax competition. The Handbook of Research on Public Finance in Europe and the MENA Region explores economic development and public finance by providing critical insight into the use of public finance and policy and illuminating the intricacies of these topics through discussion of theory, empirical work, and policy objectives. This book is ideally designed for business professionals, policy makers, financers, students and researchers in the fields of public policy and economics.
Book Synopsis Banking on Failure by : Richard S Collier
Download or read book Banking on Failure written by Richard S Collier and published by Oxford University Press. This book was released on 2020-09-01 with total page 368 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banks seem all too often involved in cases of misconduct, particularly involving the exploitation of tax systems. Banking on Failure explains why and how banks "game the system", accounting for these misconduct cases and analysing the wider implications for financial markets and tax systems. Banking on Failure: Cum-Ex and Why and How Banks Game the System explains why banks design and use structured products to exploit tax systems. It describes one of the biggest and most complex cases - the "cum-ex" scandal - in which hundreds of banks and funds from across the globe participated in the raid on the public exchequers of a number of countries, with losses in the tens of billions of euros. The book then draws on the significance of this case study, and what this tells us about modern banks and their interactions with tax systems. Banking on Failure demonstrates why the exploitation of tax systems by banks is an inevitable feature of the financial markets landscape, and suggests possible responses.
Book Synopsis Report of the Committee on Conferences by : United Nations. General Assembly. Committee on Conferences
Download or read book Report of the Committee on Conferences written by United Nations. General Assembly. Committee on Conferences and published by . This book was released on 2000 with total page 522 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Official Records written by and published by . This book was released on 2002 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Annual Review of United Nations Affairs 2009/2010 VOLUME V by : Joachim Muller
Download or read book Annual Review of United Nations Affairs 2009/2010 VOLUME V written by Joachim Muller and published by . This book was released on 2011-04-15 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: a. The set generally Since the publication of its first edition in 1950, the Annual Review of United Nations Affairs has stood as the authoritative resource for scholars, students, and practitioners researching the latest developments of that august body. From the insightful introduction, prepared each year by a distinguished expert on UN affairs, to the full-text presentation of reports and resolutions and the helpful subject index, ARUNA provides a practical tour of each year's U.N.actions and debates. The expert selection of documents by Joachim Muller and Karl Sauvant and the topic-based organization of those documents make any researcher's task much easier than the vast searching, sorting, and pruning required by the U.N.'s website. The series' topic-based organization of the materials and subject index lend invaluable guidance to all researchers. ARUNA presents comprehensive documentation of the work of the UN on an annual basis, starting in September of each yearwith the beginning of the regular sessions of the General Assembly. Coverage of the UN's key organs is provided, including the General Assembly, the Security Council, the Economic and Social Council (ECOSOC), the International Court of Justice, and the UN Secretariat. In addition, selected reports of intergovernmental bodies and expert groups are included. Solely official UN documentation is used. ARUNA occupies a special place in the publications on the work of the UN, as it allows readers toobtain an overview of the principal developments in its key organs. This makes it an important reference source for policy-makers and academic researchers. b. The 2009-2010 volumes This year's edition continues to focus on the world financial crisis and the reaction of the United Nations and the international financial system to that crisis. The Overview to this year's edition, written by Joachim Muller and Karl Sauvant, examines the changing role of the United Nations and explores waysin which the management of the financial crisis has impacted that role. The Introduction to this year's edition also examines the effects of this crisis; this Introduction is drawn from the "Report of the Commission of Experts of the President of the United Nations General Assembly on Reforms of the International Monetary and Financial System," as well as a slightly edited version of a Preface to that report written by Professor Joseph E. Stiglitz. The Introduction discusses the findings ofthe Commission and proposes the creation of a new institution, a Global Economic Coordination Council, which would be supported by an International Panel of Experts with a geographically diverse membership that would represent the interests of emerging and developing countries as well as those of developed countries. Dr. Joseph E. Stiglitz, who served as Chairman of the Commission and wrote the Preface to the Commission's Report, holds joint professorships at Columbia University's EconomicsDepartment and its Business School. He is also Co-founder and Co-President of the Initiative for Policy Dialogue. From 1997 to 2000 he was the World Bank's Senior Vice President for Development Economics and Chief Economist. From 1995 to 1997 he served as Chairman of the U.S. Council of Economic Advisers and as a member of President Clinton's cabinet. From 1993 to 1995 he was a member of the Council of Economic Advisers. He was previously a professor of economics at Stanford, Princeton, Yale,and All Souls College. Dr. Stiglitz is also a leading scholar of the economics of the public sector and was awarded the Nobel Prize in Economics in 2001 in addition to the American Economic Association's biennial John Bates Clark Award in 1979. His recent publications include Freefall: America, Free Markets, and the Sinking of the World Economy (2010), Making Globalization Work (2006), Fair Trade for All (2005), and Globalization and its Discontents (2002). The 2009-2010 volumes of ARUNA therefore also devote considerable attention to the financial crisis as well as other international crises. Among the documents in the 2009-2010 volumes are the complete General Assembly resolutions, as well as the Report and Resolutions of the Security Council and the Economic and Social Council (ECOSOC). Annual Reports of note include reports of the United Nations Children's Fund (UNICEF), the UN Development Programme and UN Population Fund, the UN High Commissioner for Human Rights, the UN HighCommissioner for Refugees, the UN Relief and Works Agency for Palestine Refugees in the Near East, and the World Food Programme. Mr. Muller and Dr. Sauvant have also selected progress reports on key peacekeeping, peace-building, and political missions, including those for Afghanistan, the Democratic Republic of the Congo, Haiti, Iraq, the Middle East, Sudan, and West Africa. c. Volume V (this volume) This volume contains the following: Chapter 1: General Assembly, Sixty-fourth Session (continued) 3. Resolutions Adopted by the General Assembly at Its Sixty-fourth Session (continued) (Resolutions 64/104 through 64/199) d. Guest Authors of previous years' editions Each annual edition of ARUNA is introduced by a Guest Author, a distinguished expert on UN affairs, who highlights the outstanding themes of the year in review. Together with an overview provided by the editors, this introduction is intended to facilitate access to the material and, above all, to make it easer for users of ARUNA to "see the forest for the trees." This year's ARUNA includes excerpts from the "Report of the Commission of Experts of the President of the United Nations General Assembly on Reforms of the International Monetary and Financial System" (21 Sept. 2009), and from a slightly edited version of a Preface to that report written by Professor Joseph E. Stiglitz. However, the roster of distinguished experts who have contributed this introduction in the past is also worthy of mention: Jose Antonio Ocampo: ARUNA 2008/2009 edition Professor Jose Antonio Ocampo is Co-President of the Initiative for Policy Dialogue. He is also Professor in the School of International and Public Affairs and Fellow of the Committee on Global Thought at Columbia University. Professor Ocampo previously held the positions of Under-Secretary-General of the United Nations for Economic and Social Affairs, Executive Secretary of the United Nations Economic Commission for Latin America and the Caribbean, and Minister of Finance, Agriculture, and Planning of Colombia. In 2009, he was a member of the Commission of Experts of the President of the United Nations General Assembly on Reforms of the International Monetary and Financial System. Professor Ocampo is also the author of numerous books and articles on macroeconomics policy and theory, economic development, international trade, and economic history. His recent publications include Stability with Growth: Macroeconomics, Liberalization and Development, with Joseph E. Stiglitz, Shari Spiegel, Ricardo Ffrench-Davis and Deepak Nayyar (New York: Oxford University Press, 2006). Jeffrey D. Sachs: ARUNA 2007/2008 edition Professor Jeffrey D. Sachs is Director of the Earth Institute at Columbia University and Special Advisor to the Secretary-General of the UN on the Millennium Development Goals. Professor Sachs's introduction to ARUNA 2007/2008 was titled "Towards a New Global Protocol on Climate Change," in which he argued that solving the climate change problem will demand four steps: scientific consensus, public awareness, the development of alternative technologies, and a global framework for action. He dealt, in particular, with the science underpinning the negotiations for a new global protocol on climate change, as a successor to the Kyoto Protocol. Professor Sachs argued that climate change crises can only be solved through the goals, leadership, and treaty mechanisms of the UN. Edward C. Luck: ARUNA 2006/2007 edition Professor Edward C. Luck is UN Special Advisor on the Responsibility to Protect and Vice President and Director of Studies at the International Peace Academy. From 1984 to 1994, he served as President and Chief Executive Officer of the UN Association of the USA (UNA-USA). Professor Luck's introduction to ARUNA 2006/2007 covered "The responsible sovereign and the responsibility to protect," in which he addressed the scope and content of what was agreed at the 2005 World Summit,the implications of the responsibility to protect (RtoP) for notions of state sovereignty, and some of the conceptual, architectural, and policy challenges then facing UN Secretary-General Ban Ki-moon's commitment to "operationalizing" the responsibility to protect and translating it "from words to deeds." Louise Frechette: ARUNA 2005/2006 edition Ms Louise Frechette is Distinguished Fellow at the Centre for International Governance Innovation, Waterloo, Ontario. Until March 2006, she was the first Deputy Secretary-General of the UN; before that, she was Permanent Representative of Canada to the UN. Ms Frechette's introduction to ARUNA 2005/2006 covered "United Nations reform: an unfinished story." As the first Deputy Secretary-General of the UN, Ms Frechette was uniquely positioned to undertake a personal assessment of what has changed and what has not changed in the past decade at the UN and why. She examined if the UN is functioning better than it was 15 years ago, why reform is so difficult to achieve and what the future holds for the institutions. Rubens Ricupero: ARUNA 2004/2005 edition Mr Rubens Ricupero is Dean of the Fundacno Armando Alvares Penteado (FAAP), Sao Paulo and was formerly Secretary-General of UN Conference on Trade and Development (UNCTAD) and Minister of Finance of Brazil. Mr Ricupero's introduction to ARUNA 2004/2005 covered "The difficulty of building consensus in an age of extremes" and examined the mysteries of the negotiating process leading to the outcome of the 2005 World Summit. Rather than a "Grand Bargain" of a comprehensive UN reform in the areas of development, security and human rights, it is argued that the Summit ended more on a note of lamentation and regret over a missed opportunity. Mr Ricupero concludes that contrary to the daring proclamation at the outset by the Secretary-General, the conditions indispensable to succeed were not in place. Indeed, it was hard to imagine that an ambitious and balanced reform package for the UN could have had any real chance of succeeding.
Book Synopsis Resolutions and Decisions of the Economic and Social Council by : United Nations
Download or read book Resolutions and Decisions of the Economic and Social Council written by United Nations and published by UN. This book was released on 2011-12 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Annual Review of United Nations Affairs by : Clyde Eagleton
Download or read book Annual Review of United Nations Affairs written by Clyde Eagleton and published by . This book was released on 2011 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: Contains the proceedings of the 1st- Institute for Annual Review of United Nations Affairs, New York University, 1949-