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Taxation Of Cross Border Services
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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.
Book Synopsis The Law of Cross-border Business Transactions by : Lutz-Christian Wolff
Download or read book The Law of Cross-border Business Transactions written by Lutz-Christian Wolff and published by Kluwer Law International. This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Law of Cross-Border Business Transactions aims at giving a structured introduction to the law and practice of investment deals (e.g., greenfield projects, M&As and hybrid forms) and of non-investment transactions (e.g., trade, technology transfer and services). Cross-border business deals are nowadays routine matters for business entities all over the world and the related legal aspects are becoming more and more complex. This book provides extensive general background information. It also covers numerous specific issues of relevance in the context of cross-border projects. Substantive law issues, procedural aspects and skills-related considerations such as contract drafting, structuring options and cross-cultural lawyering techniques are included, adding up to an unusually comprehensive and useful guide in the field. What's in this book: The author describes a wide spectrum of transaction types. He explains underlying principles from a conceptual and a comparative point of view with a focus on transactional issues, using case studies from a variety of jurisdictions to demonstrate the significance of particular aspects in the context of multi-jurisdictional legal practice. Among much else, topics include the following: international lawyering and cultural diversity; lex mercatoria; conflict of laws; letters of intent, position papers, heads of agreement, confidentiality and exclusivity agreements; structure and contents of international contracts; e-contracts and smart contracts; protection of intellectual property rights and technology transfer; trade, countertrade and trade financing; insurance; agency and distributorship; greenfield investments and M&As; competition law and merger control; employment law; corporate governance and corporate social responsibility; international taxation; and dispute settlement and cross-border enforcement of awards. This second edition updates the discussion of the different topics comprehensively. It also expands many parts and adds sections in relation to new themes that have gained importance since the publication of the first edition. In particular, it addresses legal issues arising out of the digitalization of the global economy with a special focus on choice-of-law questions, smart contracts, e-bills of lading and online dispute settlement. It also draws attention to the impact of China's Belt and Road initiative, Brexit and the 'America First' foreign policy. How this will help you: Of special value is the author's precise guidance on drafting techniques and contract practice. The clarity of the presentation, the uncompromising consistency in terms of structure and a large body of references to primary and secondary sources presented in this edition ensure that legal professionals, business managers and academics as well as other interested parties can gain easy access to comprehensive and detailed information across jurisdictions.
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).
Book Synopsis General Explanation of the Tax Reform Act of 1986 by :
Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1400 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Administering the Value-Added Tax on Imported Digital Services and Low-Value Imported Goods by : John Brondolo
Download or read book Administering the Value-Added Tax on Imported Digital Services and Low-Value Imported Goods written by John Brondolo and published by International Monetary Fund. This book was released on 2021-05-21 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: This technical note and manual (TNM) addresses the following questions: (1) What are the main challenges in administering the value-added tax on imported digital services and the measures that countries have introduced to address the challenges?; (2) What are the main challenges in administering the value-added tax on low-value imported goods and the measures that countries have introduced to address the challenges? ;and (3) What are the key tasks in implementing the measures for improving the administration of the value-added tax on imported digital services and low-value imported goods?
Book Synopsis Cross-border Consumption Taxation of Digital Supplies by : Pernilla Rendahl
Download or read book Cross-border Consumption Taxation of Digital Supplies written by Pernilla Rendahl and published by IBFD. This book was released on 2009 with total page 461 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study compares cross-border consumption taxation of digital supplies in business-to-consumer transactions from an international coordination perspective. Hence, the various classifications of digital supplies and the provisions for deciding the place of taxation are compared and examined to identify cases of double taxation and unintentional nontaxation or potential risks thereof. In addition, possible remedies for double taxation and unintentional non-taxation are discussed.
Book Synopsis Corporate Income Taxes under Pressure by : Ruud A. de Mooij
Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Book Synopsis Crossing African Borders by : Collectif
Download or read book Crossing African Borders written by Collectif and published by Centro de Estudos Internacionais. This book was released on 2017-08-04 with total page 146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is one of the results of a conference organised in Lisbon in 2011 on the theme of African borders and their relationships with migration and mobility. The selected papers are a sample of the diverse perspectives on the general theme presented at the meeting. The African Borderlands Research Network (ABORNE) promoted this event, allowing a substantial number of its members to exchange results of ongoing and long-term research. The Fundação para a Ciência e a Tecnologia (Portugal) funded the research project Borders and Identity in Africa (PTDC/AFR/098339/2008) which prepared this publication.
Book Synopsis Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition by : OECD
Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Model Tax Convention on Income and on Capital 2017 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2017 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Book Synopsis A Practical Guide to U. S. Taxation of International Transactions by : Robert Meldman
Download or read book A Practical Guide to U. S. Taxation of International Transactions written by Robert Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
Book Synopsis Taxation of International Transactions by : Charles H. Gustafson
Download or read book Taxation of International Transactions written by Charles H. Gustafson and published by West Academic Publishing. This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Book Synopsis The X Tax in the World Economy by : David F. Bradford
Download or read book The X Tax in the World Economy written by David F. Bradford and published by A E I Press. This book was released on 2004 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study explores how the tax design called the X tax could alleviate the complexities and avoidance opportunities plaguing the existing U.S. system for taxing international business income.
Book Synopsis Research Handbook on International Taxation by : Yariv Brauner
Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Book Synopsis Taxation of Canadians in America by : Dale Walters
Download or read book Taxation of Canadians in America written by Dale Walters and published by Self-Counsel Press. This book was released on 2012-11-30 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Are you a Canadian who spends your winters in the southern United States, or occasionally conducts work in the US? Many Canadians do not know that they need a work visa to legally conduct business during their stay in the United States. Even more worrisome is that they don’t know that they may be required to file taxes with the IRS. This law also applies to those telecommuting from the US for Canadian businesses. The consequences of declining to pay taxes or not obtaining a work visa can be severe. One could end up being declared an illegal immigrant and being deported!
Book Synopsis Taxation of Cross-border Services by :
Download or read book Taxation of Cross-border Services written by and published by . This book was released on 2012 with total page 927 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author examines the different conditions for tax treatment of services in India. He closely analyses statutory provisions, case law and tax treaty provisions. Further, the book offers synopses of relevant court decisions. Part I deals with the provisions of the domestic law as regards taxation of fees for technical services. Part II deals with taxation of services in terms of the provisions of the tax treaties signed by India. Part III deals with the provisions of the proposed Direct Taxes Code Bill 2010 as regards taxation of services and Branch Profits Tax.
