OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241698
Total Pages : 106 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 6.

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264241206
Total Pages : 102 pages
Book Rating : 4.2/5 (412 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-21 with total page 102 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264219129
Total Pages : 112 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report from the OECD/G20 Base Erosion and Profit Shifting project examines the issue of preventing the granting of treaty benefits in inappropriate circumstances. It includes proposed changes to the OECD Model Tax convention and summarises progress to date.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264950982
Total Pages : 302 pages
Book Rating : 4.2/5 (649 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2021-04-01 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264312382
Total Pages : 266 pages
Book Rating : 4.2/5 (643 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2019-02-14 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all Inclusive Framework members have committed to implement.This report reflects the outcome of the first peer review of the implementation ...

Preventing Treaty Abuse

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Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408385
Total Pages : 473 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Preventing Treaty Abuse by : Daniel Blum

Download or read book Preventing Treaty Abuse written by Daniel Blum and published by Linde Verlag GmbH. This book was released on 2016-09-19 with total page 473 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.

Harmful Tax Competition An Emerging Global Issue

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Author :
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.

Addressing Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

The Political Economy of Public Finance

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Author :
Publisher : Ijopec Publication
ISBN 13 : 191250300X
Total Pages : 238 pages
Book Rating : 4.9/5 (125 download)

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Book Synopsis The Political Economy of Public Finance by : Mustafa Çelen

Download or read book The Political Economy of Public Finance written by Mustafa Çelen and published by Ijopec Publication. This book was released on 2017 with total page 238 pages. Available in PDF, EPUB and Kindle. Book excerpt:

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264760911
Total Pages : 325 pages
Book Rating : 4.2/5 (647 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2024-03-20 with total page 325 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the sixth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.

Mauritius

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Publisher : International Monetary Fund
ISBN 13 : 1484331575
Total Pages : 38 pages
Book Rating : 4.4/5 (843 download)

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Book Synopsis Mauritius by : International Monetary Fund. African Dept.

Download or read book Mauritius written by International Monetary Fund. African Dept. and published by International Monetary Fund. This book was released on 2017-12-08 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper discusses how Mauritius is currently dealing with two separate tax transparency and anti-avoidance initiatives, one by the OECD-G20 and one by the European Union. Under the BEPS initiative, Mauritius has committed to including minimum standards and possibly other BEPS-compliant features into its domestic laws and bilateral double taxation avoidance agreements (DTAs). Mauritius has been involved in intensive DTA negotiations and re-negotiations. Sixteen DTAs have been added in the past 6 years. Arguably, even more important for investors has been the favorable tax framework offering benefits that are in part being challenged. Mauritius currently has a 15 percent corporate income tax (CIT) rate and a worldwide system that taxes foreign earnings but allows for foreign tax credits (FTCs), including the contested Deemed Foreign Tax Credit. Important macrofinancial linkages between the GBC sector and the financial sector present vulnerabilities that need to be managed carefully. The GBC sector is a major provider of inexpensive funding to banks, but by nature of the GBC investment pattern, these deposits are potentially highly volatile.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264989722
Total Pages : 319 pages
Book Rating : 4.2/5 (649 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2023-03-21 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.

Taxation, International Cooperation and the 2030 Sustainable Development Agenda

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Author :
Publisher : Springer Nature
ISBN 13 : 3030648575
Total Pages : 228 pages
Book Rating : 4.0/5 (36 download)

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Book Synopsis Taxation, International Cooperation and the 2030 Sustainable Development Agenda by : Irma Johanna Mosquera Valderrama

Download or read book Taxation, International Cooperation and the 2030 Sustainable Development Agenda written by Irma Johanna Mosquera Valderrama and published by Springer Nature. This book was released on 2021-03-29 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: This open access volume addresses the link between international taxation, the 2030 Sustainable Development Agenda and the medium-term revenue strategy concept. It also analyses how countries and governments can reinforce this link in current and future initiatives in international taxation, including the base erosion profit shifting project initiated by the Organization for Economic Co-operation and Development with the political mandate of the G20. It discusses the 2030 Sustainable Development Agenda that are relevant for taxation and assesses the current work done by international organizations, regional tax organizations and countries to achieve these Sustainable Development Goals. The contributions to this volume provide an interdisciplinary mix of expertise in tax law, international political economy, global governance and international relations. Through these different perspectives, this volume provides an elaborate reference and evaluation framework for multilateral cooperation on tax and development to strengthen the revenue system of developed and developing countries. This topical volume is of interest to students and researchers of the social sciences, law and economics, as well as policy makers working on taxation.

International Tax Aspects of Sovereign Wealth Investors

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194339
Total Pages : 277 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Tax Aspects of Sovereign Wealth Investors by : Richard Snoeij

Download or read book International Tax Aspects of Sovereign Wealth Investors written by Richard Snoeij and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 277 pages. Available in PDF, EPUB and Kindle. Book excerpt: An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264592679
Total Pages : 317 pages
Book Rating : 4.2/5 (645 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 written by OECD and published by OECD Publishing. This book was released on 2022-03-21 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fourth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.

Hybrid Entities in Tax Treaty Law

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Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410754
Total Pages : 696 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Hybrid Entities in Tax Treaty Law by : Sriram Govind

Download or read book Hybrid Entities in Tax Treaty Law written by Sriram Govind and published by Linde Verlag GmbH. This book was released on 2020-09-03 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241132
Total Pages : 458 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.