Booth And Schwarz Residence Domicile And Uk Taxation
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Booth and Schwarz: Residence, Domicile and UK Taxation:. by Jonathan Schwarz Pdf
This title gives the reader authoritative guidance on the legislation dealing with residence, principally the Statutory Residence Test which defines for tax purposes whether or not an individual is resident in the United Kingdom. The author, Jonathan Schwarz, is a Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems.
The issues surrounding the status of residence, non-residence and the appropriate tax liability are becoming ever more complex, Recent UK and European cases have contributed to this, and have helped to create a climate of uncertainty amongst professionals attempting to determine their client's status and tax responsibilities accurately. Booth: Residence, Domicile and UK Taxation provides a crisp analysis of this subject, and expertly examines the three underlying concepts: residence, ordinary residence and domicile. The accessible style ensures the reader can quickly grasp the key principles and fully understand the tests that can be applied to clarify tax liabilities whether individual, partnership, trust or limited company.
Booth: Residence, Domicile and UK Taxation by Jonathan Schwarz Pdf
This book provides an analysis of residence, domicile and UK taxation and examines the residence and other fiscal connections for individuals, companies and trusts. It unravels the tax residence of companies and the resolution of dual residence including specialised residence rules applied to controlled foreign companies, dual resident investing companies and transfer pricing.
Tax Implications of Brexit is an essential guide for anyone advising businesses trading in either the United Kingdom or the European Union post-Brexit. In two parts, this title provides an in-depth analysis of the tax ramifications of Brexit in both the United Kingdom and EU Member States, helping to identify immediate and future issues that could be faced post-Brexit, and how to mitigate any risks. Part One features subject-specific chapters which deal with the UK statutory regime after 2020 as well as the impact of Brexit on VAT, customs and excise duties and State Aid legislation. Part Two is split into country chapters dealing with the tax implications in the single jurisdictions (the United Kingdom and EU Member States) for cross-border investments between the United Kingdom and the EU and for UK-EU cross-border reorganisations. This book is essential reading for tax professionals advising businesses trading in the United Kingdom or in the European Union, but also tax managers of those businesses. Tax Implications of Brexit includes contributions from Barbara Belgrano, Conor Quigley QC, Julian Ghosh QC, Kelly Stricklin-Coutinho, Nicola Saccardo, Roderick Cordara QC, Timothy Lyons QC and a plethora of highly respected tax experts from EU jurisdictions.
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Automatic Exchange of Information Handbook by John Hiddleston Pdf
Automatic Exchange of Information Handbook is a practical guide to the automatic exchange of information rules legislation within the UK. Covering the requirements of the OECD Common Reporting Standard (CRS), and the US Foreign Account Tax Compliance Act (FATCA) on financial institutions, this title helps to explain: - What the key jargon means - How to work out the status of an organisation under these rules (the definition of financial institutions may include professional firms, charities and trusts) - The potential penalties and other risks of non-compliance and how to minimise those risks - How to achieve compliance, including: - How to carry out the required due diligence - How to make a report The title summarises a brief history of AEOI, the impact of Brexit, who is affected and how, due diligence requirements, and more, as well as other issues including other forms of international information exchange such as anti-money laundering rules and bi-lateral double taxation treaties. Key points are clearly highlighted throughout for easy references and flowcharts are included to support some areas of commentary. This title is essential for tax advisers, accountants, tax lawyers, financial advisers and students studying for international tax qualifications. It will also be relevant for finance and management teams in organisations which fall under these rules in practice.
Corporate Residence and International Taxation by Robert Couzin Pdf
Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.
Tax Treaty Residence of Entities by Jan Gooijer Pdf
It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.
Principles of International Taxation by Lynne Oats Pdf
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.
Tax Treaty Case Law around the Globe 2021 by Georg Kofler,Michael Lang,Alexander Rust,Jeffrey Owens,Pasquale Pistone,Josef Schuch,Karoline Spies,Claus Staringer,Alfred Storck,Peter Essers,Eric Kemmeren,Cihat Öner,Daniel Smit Pdf
A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, "Tax Treaty Case Law around the Globe 2021" is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.
Residence and Domicile of Individuals by Anonim Pdf
An explanation of the concepts of residence and domicile in UK tax law and their implications for individuals coming to or leaving the UK. Includes appendices summarizing the liability to UK income, capital gains and inheritance taxes of resident, non-resident and non-domiciled individuals.
Applying the Arm's Length Principle to Intra-group Financial Transactions by Robert Danon,Vikram Chand,Guglielmo Maisto,Amanda Pletz Pdf
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
The Oxford Handbook of International Tax Law by Florian Haase,Georg Kofler Pdf
International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
