The Meaning Of Enterprise Business And Business Profits Under Tax Treaties And Eu Tax Law

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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

The Meaning of 'Enterprise,' 'Business,' and 'Business Profits' Under Tax Treaties and Domestic Tax Law

Author : Allison Christians
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (137 download)

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Book Synopsis The Meaning of 'Enterprise,' 'Business,' and 'Business Profits' Under Tax Treaties and Domestic Tax Law by : Allison Christians

Download or read book The Meaning of 'Enterprise,' 'Business,' and 'Business Profits' Under Tax Treaties and Domestic Tax Law written by Allison Christians and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are often ill-defined and under-theorized, especially in their interaction with other regulatory areas. This U.S. Report, commissioned for a comparative volume on the subject, focuses on the use and significance of these concepts from a U.S. perspective. Part I deals with the meaning of these concepts under domestic non-tax legislation, with a particular focus on private law, commercial law, company law and bankruptcy law. Part II describes the concepts under domestic tax law with reference to relevant jurisprudence, administrative practice and doctrine. Part III discusses the concepts as interpreted for purposes of double tax conventions, with reference to specific treaty provisions, case law and literature. Part IV discusses the compatibility of domestic law provisions with their use in tax conventions and concludes.

Permanent Establishment

Author : Arvid Aage Skaar
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403520647
Total Pages : 957 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Permanent Establishment by : Arvid Aage Skaar

Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.

Taxation of Business Profits in the 21st Century

Author : Carlos Gutiérrez
Publisher :
ISBN 13 : 9789087221898
Total Pages : 342 pages
Book Rating : 4.2/5 (218 download)

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Book Synopsis Taxation of Business Profits in the 21st Century by : Carlos Gutiérrez

Download or read book Taxation of Business Profits in the 21st Century written by Carlos Gutiérrez and published by . This book was released on 2013 with total page 342 pages. Available in PDF, EPUB and Kindle. Book excerpt: "This book sheds light on a selection of issues surrounding the essential questions described above from a practical as well as from an academic perspective. The first part is dedicated to issues relating to the application of article 5 of the OECD Model and the problem of determining the existence of a permanent establishment in a state. The second part of the book relates to issues arising from article 7 of the OECD Model and the attribution of profits to a permanent establishment."--Extracted from publisher website on March 26, 2015.

Switzerland in International Tax Law

Author : Xavier Oberson
Publisher : IBFD
ISBN 13 : 9087220987
Total Pages : 457 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Switzerland in International Tax Law by : Xavier Oberson

Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).

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.

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.

Tax Treaty Case Law around the Globe 2018

Author : Eric Kemmeren
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410061
Total Pages : 478 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Tax Treaty Case Law around the Globe 2018 by : Eric Kemmeren

Download or read book Tax Treaty Case Law around the Globe 2018 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2019-06-13 with total page 478 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 35 most important tax treaty cases which were decided around the world in 2017. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2018 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

Klaus Vogel on Double Taxation Conventions

Author : Ekkehart Reimert
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

Tax Treaties around the Globe 2012

Author : Eric C.C.M. Kemmeren et al.
Publisher : IBFD
ISBN 13 : 9087221916
Total Pages : 389 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Tax Treaties around the Globe 2012 by : Eric C.C.M. Kemmeren et al.

Download or read book Tax Treaties around the Globe 2012 written by Eric C.C.M. Kemmeren et al. and published by IBFD. This book was released on 2013 with total page 389 pages. Available in PDF, EPUB and Kindle. Book excerpt: Présentation de l'éditeur : "Tax Treaty Case Law around the Globe 2012 comprises the proceedings of a conference held in Tilburg, the Netherlands on 14-16 June 2012. The book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the thirty-five most important tax treaty cases which were decided during the course of 2011 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2012 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics."

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

Author : David Orzechowski-Zölzer
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.

The Attribution of Profits to Permanent Establishments

Author : Raffaele Russo
Publisher : IBFD
ISBN 13 : 907607884X
Total Pages : 488 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis The Attribution of Profits to Permanent Establishments by : Raffaele Russo

Download or read book The Attribution of Profits to Permanent Establishments written by Raffaele Russo and published by IBFD. This book was released on 2005 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016

The principle of non-discrimination in international and European tax law

Author : Niels Bammens
Publisher : IBFD
ISBN 13 : 9087221592
Total Pages : 1151 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis The principle of non-discrimination in international and European tax law by : Niels Bammens

Download or read book The principle of non-discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.

Judicial Interpretation of Tax Treaties

Author : Carlo Garbarino
Publisher : Edward Elgar Publishing
ISBN 13 : 1785365886
Total Pages : 699 pages
Book Rating : 4.7/5 (853 download)

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Book Synopsis Judicial Interpretation of Tax Treaties by : Carlo Garbarino

Download or read book Judicial Interpretation of Tax Treaties written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2016-10-28 with total page 699 pages. Available in PDF, EPUB and Kindle. Book excerpt: Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.

Tax Cooperation in an Unjust World

Author : Allison Christians
Publisher : Oxford University Press
ISBN 13 : 0192848674
Total Pages : 209 pages
Book Rating : 4.1/5 (928 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 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.

The Concept of Permanent Establishment in the Insurance Business

Author : Daniele Frescurato
Publisher : Kluwer Law International B.V.
ISBN 13 : 940353284X
Total Pages : 430 pages
Book Rating : 4.4/5 (35 download)

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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.

Introduction to Transfer Pricing

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403514930
Total Pages : 281 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Introduction to Transfer Pricing by : Jerome Monsenego

Download or read book Introduction to Transfer Pricing written by Jerome Monsenego and published by Kluwer Law International B.V.. This book was released on 2022-11-22 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles are provided by the OECD the views of other international organisations – in particular the United Nations and the European Union – are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm’s length principle in theory and practice; transfer pricing methods; intercompany transactions involving intangibles and financial transactions; common types of transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes. This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.