The History Of Double Taxation Conventions In The Pre Beps Era

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The History of Double Taxation Conventions in the Pre-BEPS Era

Author :
Publisher :
ISBN 13 : 9789087226688
Total Pages : 1000 pages
Book Rating : 4.2/5 (266 download)

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Book Synopsis The History of Double Taxation Conventions in the Pre-BEPS Era by :

Download or read book The History of Double Taxation Conventions in the Pre-BEPS Era written by and published by . This book was released on 2021 with total page 1000 pages. Available in PDF, EPUB and Kindle. Book excerpt: The design of international tax law cannot be described without recourse to its extensive history. By looking at the evolution of tax treaties, valuable insight is gained as regards the causes behind the most recent shift towards renewed international tax coordination in the framework of the BEPS Project. This book analyses how tax treaties have evolved, from the early days of the history of international taxation until the beginning of the BEPS era, by collecting the outcome of joint research on the development of international tax law. It consists of a wide range of papers bridging the existing gap between the history of international law, economic history and the history of international cooperation.0 0In this context, it also spells out the importance of the role of early institutions such as the International Chamber of Commerce and the League of Nations, as well as the International Fiscal Association and the OEEC/OECD, and helps to highlight their fundamental influence. The book is the result of the conference 'History of Double Taxation Conventions', which took place from 3-5 July 2008 in Rust/Neusiedler See. It consists of 30 contributions exploring the development of the tax treaty practices of 30 countries and, additionally, three cross-sectional contributions.

Tax Sovereignty in the BEPS Era

Author : Sergio André Rocha
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041167080
Total Pages : 338 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha

Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

Double Non-taxation and the Use of Hybrid Entities

Author : Leopoldo Parada
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041199926
Total Pages : 490 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Double Non-taxation and the Use of Hybrid Entities by : Leopoldo Parada

Download or read book Double Non-taxation and the Use of Hybrid Entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 490 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth critique of the BEPS Action Plan 2 with regard to hybrid entities, this timely book provides a critical review of the OECD’s approach and proposes a deeply informed alternative method based on the tax policy aims of simplicity, coherence and ease of administration. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasizing the international tax context, including the application of tax treaties. Among the seminal matters covered are the following: – foundations of the concepts of double non-taxation and hybrid entities, absent of the specific limitations of domestic tax legislation; – extensive analysis based on the rules of characterization of foreign entities for tax purposes in the United States, Spain, Denmark and Germany, as well as on the Poland/United States and Canada/United States tax treaties; – detailed analysis on the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument, especially having in mind the position of developing (source) countries; and – EU tax law as part of the international context, including an extensive analysis on the EU Anti-Tax Avoidance Directive (ATAD) I and ATAD II. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding double non-taxation and hybrid entities, this analysis elaborates solutions applicable to a generality of cases worldwide, and thus hugely promotes the urgent quest for alternative solutions.

International Tax Policy and Double Tax Treaties

Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes

Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Multilateral Cooperation in Tax Law

Author : Martin Klokar
Publisher : Linde Verlag GmbH
ISBN 13 : 3709412986
Total Pages : 357 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Multilateral Cooperation in Tax Law by : Martin Klokar

Download or read book Multilateral Cooperation in Tax Law written by Martin Klokar and published by Linde Verlag GmbH. This book was released on 2023-10-03 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021-23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.

Tax Transfer Pricing

Author : Andrea Musselli
Publisher : Gruppo 24 Ore
ISBN 13 :
Total Pages : 446 pages
Book Rating : 4.2/5 (548 download)

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Book Synopsis Tax Transfer Pricing by : Andrea Musselli

Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.

International Tax at the Crossroads

Author : Craig Elliffe
Publisher : Edward Elgar Publishing
ISBN 13 : 180088902X
Total Pages : 325 pages
Book Rating : 4.8/5 (8 download)

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Book Synopsis International Tax at the Crossroads by : Craig Elliffe

Download or read book International Tax at the Crossroads written by Craig Elliffe and published by Edward Elgar Publishing. This book was released on 2023-12-11 with total page 325 pages. Available in PDF, EPUB and Kindle. Book excerpt: In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.

A Journey Through European and International Taxation

Author : Carla De Pietro
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403532076
Total Pages : 625 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis A Journey Through European and International Taxation by : Carla De Pietro

Download or read book A Journey Through European and International Taxation written by Carla De Pietro and published by Kluwer Law International B.V.. This book was released on 2024-03-06 with total page 625 pages. Available in PDF, EPUB and Kindle. Book excerpt: To some extent, because of his overlapping careers in academia and politics, the renowned tax scholar Peter Essers is known for his influential insight that ‘the effects of taxation on the political balance of power, and vice versa, are always interlinked with other phenomena, such as wars, crises, religious developments and inequalities in society’. In this widely ranging festschrift, thirty-six prominent tax scholars from all across Europe examine the legacy of Peter Essers’ research interests, from the larger philosophical, political, and social factors driving tax history to the reality of the taxing State as experienced by taxpayers and tax officials. The book’s outstanding overview of the most relevant technical and policy aspects of European and international taxation includes deeply thoughtful chapters on such topics and issues as the following: developing sustainable corporate tax governance; tax whistleblowing; transfer pricing; balancing qualitative and quantitative approaches to tax research; necessity to reach something close to ‘equal treatment’ between the upper and lower social classes; consent and democracy; tax rebellions; tax evasion and tax avoidance; taxation of cross-border remote workers and their employers; mitigation of double taxation of income earned by entertainers and sportspersons; and the international tax treaty network. More than a homage to this scholar’s far-reaching contributions, this book is remarkable for the variety and academic rigour of the chapters. The understanding its authors provide of both the broad contours and the intricacies of European and international taxation will be of inestimable value to tax practitioners, policymakers, tax consultants, and academics, as well as interested researchers in economics, political science, and sociology.

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS

Download OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS PDF Online Free

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264293086
Total Pages : 216 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

The Taxation of Pensions

Author : Robert Holzmann
Publisher : MIT Press
ISBN 13 : 0262347776
Total Pages : 521 pages
Book Rating : 4.2/5 (623 download)

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Book Synopsis The Taxation of Pensions by : Robert Holzmann

Download or read book The Taxation of Pensions written by Robert Holzmann and published by MIT Press. This book was released on 2018-08-07 with total page 521 pages. Available in PDF, EPUB and Kindle. Book excerpt: Theoretical and policy perspectives on the taxation of pension, viewed in an international context. Policy makers and academic researchers have been preoccupied in recent decades with the design of pension schemes and effective pension system reform. Relatively little attention has been given to the taxation of pensions and, more broadly, the provision of retirement income. In this book, experts from a range of countries explore the interconnection. Their contributions are especially timely, given recent demographic and political developments including population aging that lengthens the time between contribution payment and benefit receipt, the mobility of capital and labor brought about by globalization, and the complexity of pension taxation within and between countries. In shedding light on these issues, the chapters document the various forms of taxation of pension systems; use economic theory to explain both qualitative and quantitative observations; and consider whether the observed interaction of taxation and pensions is efficient. Theoretical overviews are followed by rigorous analyses of pension taxation in specific countries, including Denmark, Sweden, Portugal, Australia, Germany, the United Kingdom, and the United States. Contributors Torben M. Andersen, Spencer Bastani, Hazel Bateman, Sören Blomquist, Axel Börsch-Supan, Jorge Miguel Bravo, Gary Burtless, Rafal Chomik, Helmuth Cremer, Carl Emmerson, Csaba Feher, Bernd Genser, Robert Holzmann, Paul Johnson, Alain Jousten, Christian Keuschnigg, Eric Koepcke, George Kudrna, Jukka Lassila, Luca Micheletto, Pierre Pestieau, John Piggott, Christopher Quinn, Tarmo Valkonen, Alan Woodland

Action Plan on Base Erosion and Profit Shifting

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264202714
Total Pages : 44 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : OECD

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

INCLUSIVE GLOBAL TAX GOVERNANCE IN THE POST-BEPS ERA.

Author : SIEB. KINGMA
Publisher :
ISBN 13 : 9789087226565
Total Pages : pages
Book Rating : 4.2/5 (265 download)

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Book Synopsis INCLUSIVE GLOBAL TAX GOVERNANCE IN THE POST-BEPS ERA. by : SIEB. KINGMA

Download or read book INCLUSIVE GLOBAL TAX GOVERNANCE IN THE POST-BEPS ERA. written by SIEB. KINGMA and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Future of Multilateralism

Author : Madeleine O. Hosli
Publisher : Rowman & Littlefield
ISBN 13 : 153815529X
Total Pages : 329 pages
Book Rating : 4.5/5 (381 download)

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Book Synopsis The Future of Multilateralism by : Madeleine O. Hosli

Download or read book The Future of Multilateralism written by Madeleine O. Hosli and published by Rowman & Littlefield. This book was released on 2021-07-29 with total page 329 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Future of Multilateralism addresses current challenges and future perspectives of international and regional organizations. It aims to uncover how stable the foundations of global cooperation really are, particularly in the light of the latest unilateral and protectionist practices of international players and challenges related to COVID-19. The post–World War II global order was built on the foundations of multilateral cooperation. The establishment of international institutions is aimed at avoiding another widespread collision like the two World Wars and to ensure peace and prosperity. Hence, the multilateral system was viewed as an effective mechanism in dealing and resolving various challenges at an international or a regional level. Given the effects of COVID-19 on the global, regional, state, and individual levels are so recent, very little research has been conducted to understand the challenges many multilateral institutions are facing due to the pandemic. This book uncovers the future of such organizations and prospects for the multilateral system, of which they constitute the building blocks, in view of recent trends and developments.

International VAT/GST Guidelines

Author : Collectif
Publisher : OECD
ISBN 13 : 9264271465
Total Pages : 116 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis International VAT/GST Guidelines by : Collectif

Download or read book International VAT/GST Guidelines written by Collectif and published by OECD. This book was released on 2017-04-12 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) has become a major source of revenue for governments around the world. Some 165 countries operated a VAT at the time of the completion of the International VAT/GST Guidelines in 2016, more than twice as many as 25 years before. As VAT continued to spread across the world, international trade in goods and services has also expanded rapidly in an increasingly globalised economy. One consequence of these developments has been the greater interaction between VAT systems, along with growing risks of double taxation and unintended non-taxation in the absence of international VAT co-ordination. The International VAT/GST Guidelines now present a set of internationally agreed standards and recommended approaches to address the issues that arise from the uncoordinated application of national VAT systems in the context of international trade. They focus in particular on trade in services and intangibles, which poses increasingly important challenges for the design and operation of VAT systems worldwide. They notably include the recommended principles and mechanisms to address the challenges for the collection of VAT on cross-border sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project). These Guidelines were adopted as a Recommendation by the Council of the OECD in September 2016.

The External Tax Strategy of the EU in a Post-BEPS Environment

Author : Adolfo J. Martín Jiménez
Publisher :
ISBN 13 : 9789087225032
Total Pages : pages
Book Rating : 4.2/5 (25 download)

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Book Synopsis The External Tax Strategy of the EU in a Post-BEPS Environment by : Adolfo J. Martín Jiménez

Download or read book The External Tax Strategy of the EU in a Post-BEPS Environment written by Adolfo J. Martín Jiménez and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Harmful Tax Competition An Emerging Global Issue

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264162941
Total Pages : 82 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Harmful Tax Competition An Emerging Global Issue by : OECD

Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.

Taxing Profit in a Global Economy

Author : Michael P. Devereux
Publisher : Oxford University Press
ISBN 13 : 0198808062
Total Pages : 401 pages
Book Rating : 4.1/5 (988 download)

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Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux

Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.