Countering Harmful Tax Practices More Effectively Taking Into Account Transparency And Substance Action 5 2015 Final Report

Author : OCDE,
Publisher : OCDE
Page : 80 pages
File Size : 52,5 Mb
Release : 2015-10-12
Category : Corporations
ISBN : 9264241183

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Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report by OCDE, Pdf

Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.

Author : OECD
Publisher : OECD Publishing
Page : 82 pages
File Size : 54,9 Mb
Release : 2015-10-05
Category : Electronic
ISBN : 9789264241190

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OECD/G20 Base Erosion and Profit Shifting Project Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 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 5.

Author : OECD
Publisher : OECD Publishing
Page : 68 pages
File Size : 47,9 Mb
Release : 2014-09-16
Category : Electronic
ISBN : 9789264218970

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OECD/G20 Base Erosion and Profit Shifting Project Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance by OECD Pdf

This report on preferential tax regimes sets out the progress made to date in the context of the OECD/G20 Base Erosion and Profit Shifting Project.

Author : OECD
Publisher : OECD Publishing
Page : 128 pages
File Size : 54,6 Mb
Release : 2015-06-29
Category : Electronic
ISBN : 9789264237865

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Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance (Chinese version) by OECD Pdf

Author : Ina Kerschner,Maryte Somare
Publisher : Linde Verlag GmbH
Page : 488 pages
File Size : 44,9 Mb
Release : 2017-10-04
Category : Law
ISBN : 9783709409046

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Taxation in a Global Digital Economy by Ina Kerschner,Maryte Somare Pdf

Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.

Author : Kyriazis
Publisher : Oxford University Press
Page : 289 pages
File Size : 44,7 Mb
Release : 2023-09-21
Category : Law
ISBN : 9780198878292

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Fiscal State Aid Law and Harmful Tax Competition in the Euro by Kyriazis Pdf

The intersection between fiscal state aid and taxation has become more topical than ever. Mounting financial crises have left EU Member States scrambling to increase their tax revenue, balance their budgets, and attract capital. Taking advantage of these trends, multinational enterprises have lobbied for favourable tax arrangements, raising questions about the breadth of control the Commission can and should practise. To address egregious instances of favourable taxation, the Commission has tried to simultaneously use soft law and deploy Treaty rules on state aid. Fiscal State Aid Law and Harmful Tax Competition in the EU examines the use of state aid rules against national tax measures. Kyriazis's book presents a targeted investigation of these measures in two parts. The first part addresses Commission decisions and ECJ judgments of the early 2000s, which the author calls the "first wave". The second part consists of all the recent Commission decisions and investigations into tax schemes and individual tax rulings, most notably the Apple, Fiat, Starbucks, and Amazon investigations, which Kyriazis labels the "second wave". The characteristics and common threads of each wave are set out, their similarities and differences dissected, and their nexus to the EU's fight against harmful tax competition explored. Containing a thorough analysis of the legal concept of fiscal state aid under Article 107(1) of the Treaty on the Functioning of the European Union, this book will be of interest to scholars of European and International Tax law and practitioners working in the field of European competition law.

Author : OECD
Publisher : OECD Publishing
Page : 48 pages
File Size : 41,9 Mb
Release : 2017-10-16
Category : Electronic
ISBN : 9789264283954

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OECD/G20 Base Erosion and Profit Shifting Project Harmful Tax Practices - 2017 Progress Report on Preferential Regimes Inclusive Framework on BEPS: Action 5 by OECD Pdf

This progress report is an update to the 2015 BEPS Action 5 report and contains the results of the review of all Inclusive Framework members' preferential tax regimes that have been identified.

Author : OECD
Publisher : OECD Publishing
Page : 82 pages
File Size : 49,8 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.

Author : OECD
Publisher : OECD Publishing
Page : 462 pages
File Size : 45,7 Mb
Release : 2020-12-15
Category : Electronic
ISBN : 9789264538054

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OECD/G20 Base Erosion and Profit Shifting Project Harmful Tax Practices – 2019 Peer Review Reports on the Exchange of Information on Tax Rulings Inclusive Framework on BEPS: Action 5 by OECD Pdf

BEPS Action 5 is one of the four minimum standards which all members of the OECD/G20 Inclusive Framework on BEPS have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in the absence of transparency, could give rise to BEPS concerns.

Author : OECD
Publisher : OECD Publishing
Page : 611 pages
File Size : 44,8 Mb
Release : 2019-12-23
Category : Electronic
ISBN : 9789264395138

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OECD/G20 Base Erosion and Profit Shifting Project Harmful Tax Practices – 2018 Peer Review Reports on the Exchange of Information on Tax Rulings Inclusive Framework on BEPS: Action 5 by OECD Pdf

BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in the absence of transparency, could give rise to BEPS concerns. Over 135 jurisdictions have joined the Inclusive Framework and take part in the peer review to assess their compliance with the transparency framework.

Author : Thierry Bovier,Bernard David,Pierre Kihn,Olivier Laidebeur
Publisher : Éditions Larcier
Page : 116 pages
File Size : 47,9 Mb
Release : 2019-06-04
Category : Law
ISBN : 9782879984322

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Intellectual Property in Luxembourg by Thierry Bovier,Bernard David,Pierre Kihn,Olivier Laidebeur Pdf

Every company creates intellectual property but without always realising it. In today’s knowledge-based economy, intellectual property is a strategic and essential asset that ensures the development and durability of a company. It is important to protect this asset by creating registered intellectual property rights. Intellectual Property in Luxembourg sets out the legal aspects and tax advantages, together with practical action points on how to implement an intellectual property strategy within a company. The book explains the tax and other advantages of Luxembourg, a place where innovation and entrepreneurship are valued and encouraged. Readers can use this as a practical guide to fully optimise the management of their IP rights.

Author : Kuźniacki, Błażej
Publisher : Edward Elgar Publishing
Page : 385 pages
File Size : 48,6 Mb
Release : 2022-08-12
Category : Law
ISBN : 9781802206074

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Beneficial Ownership in International Taxation by Kuźniacki, Błażej Pdf

This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Błażej Kuźniacki presents a route towards an international autonomous meaning of beneficial ownership, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity.

Author : Philip G. Alston,Nikki R. Reisch
Publisher : Oxford University Press
Page : 496 pages
File Size : 54,5 Mb
Release : 2019-04-11
Category : Law
ISBN : 9780190882242

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Tax, Inequality, and Human Rights by Philip G. Alston,Nikki R. Reisch Pdf

For the first time, Human Rights and Tax in an Unequal World brings together works by human rights and tax law experts, to illustrate the linkages between the two fields and to reveal their mutual relevance in tackling economic, social, and political inequalities. Against the backdrop of systemic corporate tax avoidance, the widespread use of tax havens, persistent pressures to embrace austerity policies, and growing gaps between the rich and poor, this book encourages readers to understand fiscal policy as human rights policy, with profound consequences for the wellbeing of citizens around the world. The essays collected examine where the foundational principles of tax law and human rights law intersect and diverge; discuss the cross-border nature and human rights impacts of abusive practices like tax avoidance and evasion; question the role of states in bringing transparency and accountability to tax policies and practices; highlight the responsibility of private sector actors for the consequences of tax laws; and critically evaluate certain domestic tax rules through the lens of equality and non-discrimination. The contributing scholars and practitioners explore how an international human rights framework can anchor debates around international tax reform and domestic fiscal consolidation in existing state obligations. They address what human rights law requires of state tax policies, and what a state's tax laws and loopholes mean for the enjoyment of human rights within and outside its borders. Ultimately, tax and human rights both turn on the relationship between the individual and the state, and thus both fields face crises as the social contract frays and populist, illiberal regimes are on the rise.

Author : International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept.
Publisher : International Monetary Fund
Page : 91 pages
File Size : 54,6 Mb
Release : 2019-03-10
Category : Business & Economics
ISBN : 9781498302258

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Corporate Taxation in the Global Economy by International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept. Pdf

The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities.

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 47,5 Mb
Release : 2022-11-22
Category : Law
ISBN : 9789403514932

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Introduction to Transfer Pricing by Jerome Monsenego Pdf

Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles are provided by the OECD the views of other international organisations – in particular the United Nations and the European Union – are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm’s length principle in theory and practice; transfer pricing methods; intercompany transactions involving intangibles and financial transactions; common types of transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes. This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.