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Committee Of Experts On International Cooperation In Tax Matters Fifth Session Geneva 19 23 October 2009
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Book Synopsis Special Features of the UN Model Convention by : Anna Binder
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 642 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.
Book Synopsis Annual Review of United Nations Affairs 2009/2010 VOLUME I by : Joachim Muller
Download or read book Annual Review of United Nations Affairs 2009/2010 VOLUME I written by Joachim Muller and published by . This book was released on 2011-04-15 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: a. The set generallySince 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 adistinguished 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 organizationof 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 year with 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 Economicand 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 itallows readers to obtain 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 volumesThis 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 andexplores ways in 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 slightlyedited version of a Preface to that report written by Professor Joseph E. Stiglitz. The Introduction discusses the findings of the 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 ageographically 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 Economics Department and its Business School. He is also Co-founder and Co-President of the Initiative for Policy Dialogue. From 1997to 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 BatesClark 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 theEconomic 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 High Commissioner for Refugees, the UN Relief and Works Agency forPalestine 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 I (this volume)This volume contains the following:Note: ARUNA 2009/2010Overview: The United Nations Year 2009/2010: Shift from center stage - Joachim Muller and Karl P. SauvantIntroduction: The United Nations and the international financial crisis: Extracts from the final report produced by 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 from a preface written byJoseph E. StiglitzCalendar of Conferences and Meetings of the United Nations, 15 September 2009 to 16 September 2010List of AbbreviationsChapter 1: General Assembly, Sixty-fourth Session1. Statement to the General Assembly by Mr. Ali Abdussalam Treki, President of the General Assembly, following the opening of the sixty-fourth session, A/64/PV1, 15 September 20092. Agenda of the sixty-fourth session of the General Assembly, A/64/251, 18 September 2009, and Add.1, 1 December 20093. Resolutions Adopted by the General Assembly at Its Sixty-fourth Session (Resolutions 64/1 through 64/103)d. Guest Authors of previous years'' editionsEach 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, tomake 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 aslightly 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 editionProfessor 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-Generalof 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 theUnited 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 includeStability 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 editionProfessor 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 heargued 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 climatechange, 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 editionProfessor 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''sintroduction 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 theconceptual, 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 editionMs 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 ARUNA2005/2006 covered "United Nations reform: an unfinished story." As the first Deputy Secretary-General of the UN, Ms Frechette was
Book Synopsis Annual Review of United Nations Affairs 2008/2009 by : Joachim Muller
Download or read book Annual Review of United Nations Affairs 2008/2009 written by Joachim Muller and published by . This book was released on 2010-04-15 with total page 454 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. Theexpert 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 a comprehensive documentation of the work of the UN on an annual basis, starting in September of each year with 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 - it allows readers to obtain an overview ofthe principal developments in its key organs. This makes it an important reference source for policy-makers and academic researchers. The highlight of this year's edition is the introductory essay written by the highly esteemed Jose Antonio Ocampo, who is Professor of Professional Practice in International and Public Affairs, Director of the Program in Economic and Political Development at the School of International and Public Affairs, and Fellow of the Committee on Global Thought, ColumbiaUniversity. 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 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 numerousbooks 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). Professor Ocampo, relying on his expertise as a policy economist and his own considerable experience working on economic issues at the United Nations, has written an incisive introductory essay focusing on the United Nations and the global economic crisis. Professor Ocampo's essay examines the history of the economic policy recommendations of UN institutions and concludes that they have often been more far-sighted and accurate than those of the Bretton Woods Institutions, including the World Bank and the International Monetary Fund. He applies this analysis in particular to the recent global financial crisis, and shows how the Monterrey Consensus of 2002, which once again made the UN a forum for global economic issues, gave serious consideration to the concerns of developing countries and set many goals that might have helped to stave off the global financial crisis if they had been more actively pursued. Professor Ocampo also examines the UN's role in the wake of the global financial meltdown, particularly with regard to the Doha follow-up Conference and the Commission of Experts on Reforms of the International Monetary and Financial System, convened by the General Assembly and led by Joseph Stiglitz. In spite of some resistance to these initiatives from the United States and other developed countries, Professor Ocampo advocates in this essay for a more influential role for the UN's institutions in global financial reform, especially in light of their superior track record in anticipating economic problems resulting from "the inherent tendency of financial markets to experience boom-bust cycles." The 2008-2009 volumes of ARUNA therefore also devote considerable attention to the financial crisis as well as other international crises. Among the documents in the 2008-2009 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 HumanRights, the UN High Commissioner for Refugees, the UN Relief and Works Agency for Palestine Refugee 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, Kosovo, the Middle East, Somalia, Sudan, and West Africa. 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". As has been mentioned above, ARUNA is fortunate this year to have Jose Antonio Ocampo as the author of its introduction, but the roster of distinguished experts who have contributed this introduction in the past is also worthy of mention: 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 reformin 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 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 Handbook of Accounting and Development by : Trevor Hopper
Download or read book Handbook of Accounting and Development written by Trevor Hopper and published by Edward Elgar Publishing. This book was released on 2012-01-01 with total page 337 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'The Handbook of Accounting and Development examines the major areas of accounting and development (financial reporting, management control, taxation, education) in both the public and private sectors. The four editors have written two of the chapters, including the "Introduction" which is more substantial and useful than an average introduction. The remaining 14 chapters are contributed by 22 distinguished authors who work in nine different countries. The quality of the writing is high throughout. The Handbook should be warmly welcomed by policy-makers and academics, especially those of us who have not paid enough attention to such matters in the past.' – Christopher Nobes, Royal Holloway, University of London, UK 'Trevor Hopper and his colleagues provide a central point of reference for research into accounting and development. Definitive chapters from internationally recognised authors (including Marcia Annisette, Kerry Jacobs, Chris Poullaos, Brendan O'Dwyer, Chibuike Uche and Jeffrey Unerman) cover the full range of issues from the role of capital markets in development, through accounting professionalization, to taxation and transfer pricing. Contributions from authors working for donors and non-governmental organisations provide a useful practical dimension that builds on the more academic chapters.' – Christopher Napier, Royal Holloway, University of London, UK This innovative and informative Handbook brings together leading international researchers on accounting and development to review empirical evidence, issues, policies and practices both past and present. The perspectives of the expert contributors reflect the strong growth of research on the topic, as accounting is increasingly recognised as an important factor in development. The book draws commentary and analyses together to inform future research, practice and policy and raises awareness of the actual and potential role of accounting in formulating and executing development policy. With theoretical and empirically focused chapters, this Handbook will appeal to academics and postgraduate students in accounting and development studies, practitioners, policymakers and development partners.
Author :Graduate Institute of International and Development Studies Publisher :Springer ISBN 13 :0230314015 Total Pages :237 pages Book Rating :4.2/5 (33 download)
Book Synopsis International Development Policy: Energy and Development by : Graduate Institute of International and Development Studies
Download or read book International Development Policy: Energy and Development written by Graduate Institute of International and Development Studies and published by Springer. This book was released on 2011-06-14 with total page 237 pages. Available in PDF, EPUB and Kindle. Book excerpt: Co-published with The Graduate Institute, this book examines how energy issues have intensified with modern development, how they shape geopolitics and access to energy in Africa, and how inconsistent energy governance really is. It discusses energy policy options in developing and emerging countries and questions the role of development aid.
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 2010-10-14 with total page 164 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Goods and Services Tax in India by : R. Kavita Rao
Download or read book Goods and Services Tax in India written by R. Kavita Rao and published by Cambridge University Press. This book was released on 2019-05-23 with total page 217 pages. Available in PDF, EPUB and Kindle. Book excerpt: Studies the evolution of GST in India since the Report of the Indirect Taxation Enquiry Committee of 1977.
Book Synopsis United Nations Handbook 2010 by : Naciones Unidas
Download or read book United Nations Handbook 2010 written by Naciones Unidas and published by . This book was released on 2010 with total page 432 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Yearbook of the United Nations by : United Nations
Download or read book Yearbook of the United Nations written by United Nations and published by . This book was released on 2009 with total page 1616 pages. Available in PDF, EPUB and Kindle. Book excerpt: Issue for 1946-47 includes a summary of the organization's activities from its inception to July 1, 1947.
Book Synopsis Scholarship, Practice and Education in Comparative Law by : John H. Farrar
Download or read book Scholarship, Practice and Education in Comparative Law written by John H. Farrar and published by Springer Nature. This book was released on 2019-10-03 with total page 223 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines how law functions in a multitude of facets and dimensions. The contributions shed light on the study of comparative law in legal scholarship, the relevance of comparative law in legal practice, and the importance of comparative law in legal education. The book will particularly appeal to those engaged in the teaching and scholarship of comparative law, and those seeking to uncover the various significant dimensions of the workings of law. The book is organised in three parts. Part I addresses scholarship, with contributors examining comparative legal issues as critique and from a theoretical framework. Part II outlines practice, with contributors discussing the function of comparative law in such comparatively diverse areas as international arbitration, environment, and the rule of law. Part III appraises comparative law in education.
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 2009 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by : United Nations
Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
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 411 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.
Download or read book The PGA Handbook written by Nicole Ruder and published by . This book was released on 2011-06-30 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Committee of Experts on International Cooperation in Tax Matters by : United Nations
Download or read book Committee of Experts on International Cooperation in Tax Matters written by United Nations and published by UN. This book was released on 2010-04-22 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The document presents the Report on the Fifth Session (19-23 October 2009) of the Committee of Experts on International Cooperation in Tax Matters Issues.
Download or read book Our Common Future written by and published by . This book was released on 1990 with total page 400 pages. Available in PDF, EPUB and Kindle. Book excerpt:
