Classifying Entities And The Meaning Of Tax Transparency

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Classifying Entities and the Meaning of 'Tax Transparency'

Michael McGowan
Classifying Entities and the Meaning of Tax Transparency Book PDF

Author : Michael McGowan
Publisher : Kluwer Law International B.V.
Page : 414 pages
File Size : 48,7 Mb
Release : 2023-01-10
Category : Law
ISBN : 9789403537443

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Classifying Entities and the Meaning of 'Tax Transparency' by Michael McGowan Pdf

Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.

Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions

OECD
Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 224 pages
File Size : 54,6 Mb
Release : 2010-07-06
Category : Electronic
ISBN : 9789264088016

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Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions by OECD Pdf

This handbook is intended to assist the assessment teams and the reviewed jurisdictions that are participating in the Global Forum on Transparency and Exchange of Information (the “Global Forum”) peer reviews and non-member reviews.

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition

OECD
Standard for Automatic Exchange of Financial Account Information in Tax Matters Second Edition Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 324 pages
File Size : 52,7 Mb
Release : 2017-03-27
Category : Electronic
ISBN : 9789264267992

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Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition by OECD Pdf

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.

A Beneficial Ownership Implementation Toolkit

Organization for Economic Cooperation and Development,Inter American Development Bank
A Beneficial Ownership Implementation Toolkit Book PDF

Author : Organization for Economic Cooperation and Development,Inter American Development Bank
Publisher : Inter-American Development Bank
Page : 51 pages
File Size : 52,5 Mb
Release : 2019-05-21
Category : Political Science
ISBN : 8210379456XXX

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A Beneficial Ownership Implementation Toolkit by Organization for Economic Cooperation and Development,Inter American Development Bank Pdf

In 2016, the G20 called on the FATF and the Global Forum to propose ways to improve the implementation of the international standards on transparency, including on the availability of beneficial ownership information, and its international exchange. The Global Forum developed a framework of proposed actions to answer that call, including a plan to facilitate effective implementation through examples of good implementation and technical assistance. This toolkit is in furtherance of the Global Forum’s commitment to support countries’ effective implementation. It is intended to help jurisdictions to develop an understanding of the beneficial ownership concepts contained in the international standards of transparency and exchange of information, and for use in conjunction with technical assistance seminars. It will support policy and implementation discussions in conjunction with capacity building workshops and technical assistance activities carried out by the Global Forum Secretariat as well as other supporting international organizations.

Tax Law Design and Drafting, Volume 1

Mr.Victor Thuronyi
Tax Law Design and Drafting Volume 1 Book PDF

Author : Mr.Victor Thuronyi
Publisher : International Monetary Fund
Page : 534 pages
File Size : 41,7 Mb
Release : 1996-08-23
Category : Business & Economics
ISBN : 1557755876

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Tax Law Design and Drafting, Volume 1 by Mr.Victor Thuronyi Pdf

Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Double non-taxation and the use of hybrid entities

Leopoldo Parada
Double non taxation and the use of hybrid entities Book PDF

Author : Leopoldo Parada
Publisher : Kluwer Law International B.V.
Page : 531 pages
File Size : 54,8 Mb
Release : 2023-12-11
Category : Law
ISBN : 9789403546766

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Double non-taxation and the use of hybrid entities by Leopoldo Parada Pdf

The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. 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 emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation 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; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. 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 hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.

Harmful Tax Competition An Emerging Global Issue

OECD
Harmful Tax Competition An Emerging Global Issue Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 82 pages
File Size : 45,6 Mb
Release : 1998-05-19
Category : Electronic
ISBN : 9789264162945

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Harmful Tax Competition An Emerging Global Issue by OECD Pdf

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.

Transparency in Government Operations

Mr.J. D. Craig,Mr.George Kopits
Transparency in Government Operations Book PDF

Author : Mr.J. D. Craig,Mr.George Kopits
Publisher : International Monetary Fund
Page : 50 pages
File Size : 53,7 Mb
Release : 1998-02-03
Category : Business & Economics
ISBN : 9781557756978

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Transparency in Government Operations by Mr.J. D. Craig,Mr.George Kopits Pdf

Transparency in government operations is widely regarded as an important precondition for macroeconomic fiscal sustainability, good governance, and overall fiscal rectitude. Notably, the Interim Committee, at its April and September 1996 meetings, stressed the need for greater fiscal transparency. Prompted by these concerns, this paper represents a first attempt to address many of the aspects of transparency in government operations. It provides an overview of major issues in fiscal transparency and examines the IMF's role in promoting transparency in government operations.

Action Plan on Base Erosion and Profit Shifting

OECD
Action Plan on Base Erosion and Profit Shifting Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 44 pages
File Size : 45,5 Mb
Release : 2013-07-19
Category : Electronic
ISBN : 9789264202719

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Action Plan on Base Erosion and Profit Shifting by OECD Pdf

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

International Taxation of Trust Income

Mark Brabazon
International Taxation of Trust Income Book PDF

Author : Mark Brabazon
Publisher : Cambridge University Press
Page : 417 pages
File Size : 42,8 Mb
Release : 2019-05-02
Category : Law
ISBN : 9781108492256

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International Taxation of Trust Income by Mark Brabazon Pdf

This 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 and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

Hybrid Entities in Tax Treaty Law

Sriram Govind,Jean-Philippe Van West
Hybrid Entities in Tax Treaty Law Book PDF

Author : Sriram Govind,Jean-Philippe Van West
Publisher : Linde Verlag GmbH
Page : 696 pages
File Size : 42,5 Mb
Release : 2020-09-03
Category : Law
ISBN : 9783709410752

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Hybrid Entities in Tax Treaty Law by Sriram Govind,Jean-Philippe Van West Pdf

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.

Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition

Peter H. Blessing,Ansgar A. Simon
Tax Planning for International Mergers Acquisitions Joint Ventures and Restructurings 5th Edition Book PDF

Author : Peter H. Blessing,Ansgar A. Simon
Publisher : Kluwer Law International B.V.
Page : 7048 pages
File Size : 46,8 Mb
Release : 2020-03-10
Category : Law
ISBN : 9789041190734

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Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition by Peter H. Blessing,Ansgar A. Simon Pdf

Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon

International Commercial Tax

Peter Harris,David Oliver
International Commercial Tax Book PDF

Author : Peter Harris,David Oliver
Publisher : Cambridge University Press
Page : 520 pages
File Size : 54,6 Mb
Release : 2010-07-22
Category : Law
ISBN : 0521853117

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International Commercial Tax by Peter Harris,David Oliver Pdf

Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.

OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

OECD
OECD G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country by Country Reporting Action 13 2015 Final Report Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 72 pages
File Size : 44,7 Mb
Release : 2015-10-05
Category : Electronic
ISBN : 9789264241480

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OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report by OECD Pdf

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 13.

International Classification of Non-Tariff Measures 2019

United Nations
International Classification of Non Tariff Measures 2019 Book PDF

Author : United Nations
Publisher : United Nations
Page : 96 pages
File Size : 49,6 Mb
Release : 2019-10-14
Category : Political Science
ISBN : 9789210042000

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International Classification of Non-Tariff Measures 2019 by United Nations Pdf

Non-tariff measures are generally defined as policy measures other than ordinary customs tariffs that can potentially have an economic effect on international trade in goods, changing quantities traded, or prices or both. Since this definition is broad, a detailed classification is of critical importance so as to better identify and distinguish among the various forms of non-tariff measures. The classification of non-tariff measures presented here is a taxonomy of all those measures considered relevant in international trade today. It builds on an old UNCTAD classification known as the Coding System of Trade Control Measures and was developed by several international organizations forming what is called the MAST group (Multi-Agency Support Team) set up to support the Group of Eminent Persons on Non-tariff Barriers established by the Secretary General of UNCTAD in 2006. The MAST team discussed and proposed this classification, and is composed of: FAO, IMF, ITC, OECD, UNCTAD, UNIDO, World Bank and WTO. The classification is seen as evolving and should adapt to the reality of international trade and data collection needs.