Cross-Border Taxation of Permanent Establishments

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041168389
Total Pages : 340 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Cross-Border Taxation of Permanent Establishments by : Andreas Waltrich

Download or read book Cross-Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.

International Company Taxation and Tax Planning

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Author :
Publisher :
ISBN 13 : 9789041145567
Total Pages : 0 pages
Book Rating : 4.1/5 (455 download)

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Book Synopsis International Company Taxation and Tax Planning by : Dieter Endres

Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

Principles of International Taxation

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Author :
Publisher : Bloomsbury Publishing
ISBN 13 : 1526519577
Total Pages : 709 pages
Book Rating : 4.5/5 (265 download)

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Book Synopsis Principles of International Taxation by : Lynne Oats

Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 709 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.

International Taxation Handbook

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Author :
Publisher : Elsevier
ISBN 13 : 0750683716
Total Pages : 391 pages
Book Rating : 4.7/5 (56 download)

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Book Synopsis International Taxation Handbook by : Colin Read

Download or read book International Taxation Handbook written by Colin Read and published by Elsevier. This book was released on 2007-04-13 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.

Taxes on Immovable Property

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Author :
Publisher : Paris, France : Organisation for Economic Co-operation and Development ; [Washington, D.C. : Sales agents, OECD Publications and Information Center]
ISBN 13 :
Total Pages : 212 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Taxes on Immovable Property by : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs

Download or read book Taxes on Immovable Property written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Paris, France : Organisation for Economic Co-operation and Development ; [Washington, D.C. : Sales agents, OECD Publications and Information Center]. This book was released on 1983 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: Survey of taxes on immovable property. Reviews the major policy issues raised in the taxation of land and buildings and compares the main provision of property tax systems in 15 OECD Member countries.

Tax By Design

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Publisher : Oxford University Press
ISBN 13 : 0199553742
Total Pages : 552 pages
Book Rating : 4.1/5 (995 download)

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Book Synopsis Tax By Design by : Stuart Adam

Download or read book Tax By Design written by Stuart Adam and published by Oxford University Press. This book was released on 2011-09 with total page 552 pages. Available in PDF, EPUB and Kindle. Book excerpt: Based on the findings of a commission chaired by James Mirrlees, this volume presents a coherent picture of tax reform whose aim is to identify the characteristics of a good tax system for any open developed economy, assess the extent to which the UK tax system conforms to these ideals, and recommend how it might be reformed in that direction.

The Effects of Taxation on Multinational Corporations

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Author :
Publisher : University of Chicago Press
ISBN 13 : 0226241874
Total Pages : 338 pages
Book Rating : 4.2/5 (262 download)

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Book Synopsis The Effects of Taxation on Multinational Corporations by : Martin Feldstein

Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

Global Tax Revolution

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Author :
Publisher : Cato Institute
ISBN 13 : 1933995181
Total Pages : 267 pages
Book Rating : 4.9/5 (339 download)

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Book Synopsis Global Tax Revolution by : Chris R. Edwards

Download or read book Global Tax Revolution written by Chris R. Edwards and published by Cato Institute. This book was released on 2008 with total page 267 pages. Available in PDF, EPUB and Kindle. Book excerpt: Introduction -- Capital explosion -- Tax cut revolution -- Flat tax club -- Mobile brains and mobile wealth -- Taxing businesses in the global economy -- The economics of tax competition -- The battle for freedom and competition -- The moral case for tax competition -- Options for U.S. policy.

Taxation

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Publisher : Oxford University Press, USA
ISBN 13 : 0199683697
Total Pages : 153 pages
Book Rating : 4.1/5 (996 download)

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Book Synopsis Taxation by : Stephen Smith

Download or read book Taxation written by Stephen Smith and published by Oxford University Press, USA. This book was released on 2015 with total page 153 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax revenues pay for many public services, including roads, health care, and education. However, it has become a contentious political issue of public debate. In this volume, Stephen Smith explains its history and its main principles; arguing that we'd all benefit from an understanding of the role of taxation in society.

Taxing Profit in a Global Economy

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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.

The Taxation of Corporate Groups Under Consolidation

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Author :
Publisher : Cambridge University Press
ISBN 13 : 1107033497
Total Pages : 339 pages
Book Rating : 4.1/5 (7 download)

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Book Synopsis The Taxation of Corporate Groups Under Consolidation by : Antony Ting

Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by Cambridge University Press. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.

International Aspects of U.S. Income Taxation

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Author :
Publisher :
ISBN 13 : 9780692249635
Total Pages : pages
Book Rating : 4.2/5 (496 download)

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Book Synopsis International Aspects of U.S. Income Taxation by : John P. Steines, Jr.

Download or read book International Aspects of U.S. Income Taxation written by John P. Steines, Jr. and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Consumption Tax Trends

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Author :
Publisher : OECD
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.:/5 (31 download)

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Book Synopsis Consumption Tax Trends by : Organisation for Economic Co-operation and Development

Download or read book Consumption Tax Trends written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1997 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt: General consumption taxes now account for nearly 20% of tax revenues of OECD countries. Only USA and Australia of OECD countries do not have a general consumption tax.

Tax Progression in OECD Countries

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Publisher : Springer
ISBN 13 : 9783642447143
Total Pages : 0 pages
Book Rating : 4.4/5 (471 download)

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Book Synopsis Tax Progression in OECD Countries by : Christian Seidl

Download or read book Tax Progression in OECD Countries written by Christian Seidl and published by Springer. This book was released on 2014-08-09 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: ​This is the first book that performs international and intertemporal comparisons of uniform tax progression with empirical data. While conventional measures of tax progression suffer from serious disadvantages for empirical analyses, this book extends uniform measures to progression comparisons of countries with different income distributions. Tax progression is analyzed in terms of Lorenz curve and Suits curve equivalents of net incomes and taxes. The authors derive six distinct definitions of the relation "is more progressive than", which are then utilized for an empirical analysis of 13 countries included in the Luxembourg Income Study (LIS). In two thirds of all international comparisons of tax progression, the authors report a clear ranking of the respective countries in terms of progression dominance. Tax based definitions of greater progressivity perform best. These observations are yet reinforced by statistical tests. The book also provides an account of the institutional background of the involved countries in order to facilitate the interpretation of the data. Moreover, the authors conduct intertemporal comparisons of tax progression for selected countries and perform a sensitivity analysis with respect to the parameterization of the equivalence scale.

International Comparison of Australia's Taxes

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Author :
Publisher :
ISBN 13 : 9780642743398
Total Pages : 415 pages
Book Rating : 4.7/5 (433 download)

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Book Synopsis International Comparison of Australia's Taxes by : Richard F. E. Warburton

Download or read book International Comparison of Australia's Taxes written by Richard F. E. Warburton and published by . This book was released on 2006 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: Concludes that although Australia is in general a low-tax country, company income, property and transaction taxes are well above the OECD average.

International Taxation of Trust Income

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Author :
Publisher : Cambridge University Press
ISBN 13 : 9781108729178
Total Pages : 0 pages
Book Rating : 4.7/5 (291 download)

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Book Synopsis International Taxation of Trust Income by : Mark Brabazon

Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2022-06-30 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.

International VAT/GST Guidelines

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264272040
Total Pages : 0 pages
Book Rating : 4.2/5 (72 download)

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Book Synopsis International VAT/GST Guidelines by : OECD

Download or read book International VAT/GST Guidelines written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper set forth internationally agreed principles and standards for the value added tax (VAT) treatment of the most common types of international transactions, with a particular focus on trade in services and intangibles. Its aim is to minimise inconsistencies in the application of VAT in a cross-border context with a view to reducing uncertainty and risks of double taxation and unintended non-taxation in international trade. It also includes the recommended principles and mechanisms to address the challenges for the collection of VAT on crossborder 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).