International Business Taxation

Author : Ulrich Schreiber
Publisher : Springer Science & Business Media
Page : 179 pages
File Size : 42,7 Mb
Release : 2013-01-30
Category : Business & Economics
ISBN : 9783642363061

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International Company Taxation by Ulrich Schreiber Pdf

The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

Author : Sol Picciotto
Publisher : Praeger
Page : 424 pages
File Size : 41,6 Mb
Release : 1992-03-02
Category : Business & Economics
ISBN : UCSD:31822015164999

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International Business Taxation by Sol Picciotto Pdf

This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

Author : William John Gibbons
Publisher : Unknown
Page : 200 pages
File Size : 55,7 Mb
Release : 1957
Category : Corporations, American
ISBN : UOM:49015000414483

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Tax Factors in Basing International Business Abroad by William John Gibbons Pdf

Author : Michael P. Devereux,Alan J. Auerbach,Michael Keen,Paul Oosterhuis,John Vella,Wolfgang Schön
Publisher : Oxford University Press
Page : 401 pages
File Size : 45,6 Mb
Release : 2020-09-29
Category : Business & Economics
ISBN : 9780198808060

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Taxing Profit in a Global Economy by Michael P. Devereux,Alan J. Auerbach,Michael Keen,Paul Oosterhuis,John Vella,Wolfgang Schön Pdf

The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.

Author : Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 573 pages
File Size : 50,5 Mb
Release : 2018
Category : Income tax
ISBN : 0433495642

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International Taxation in Canada by Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie Pdf

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 448 pages
File Size : 52,5 Mb
Release : 2020-02-20
Category : Law
ISBN : 9789403510958

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International Taxation of Banking by John Abrahamson Pdf

Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Author : Adam Starchild
Publisher : Springer
Page : 152 pages
File Size : 44,5 Mb
Release : 2016-07-27
Category : Business & Economics
ISBN : 9781349133420

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Tax Havens for International Business by Adam Starchild Pdf

Tax Havens for International Business is a special management report that shows how the establishment of a tax haven operation, in any of many locations worldwide, can save more money than any internal tax-shelter programme. This volume provides a comprehensive, step-by-step plan that simplifies the myriad complexities surrounding the formation and incorporation of branch offices and subsidiary companies within such tax havens as the Bahamas, Bermuda, the Cayman Islands, Greece, Hong Kong, Luxembourg, Malta, The Netherlands, Panama, Puerto Rico, and Switzerland. In addition, it presents detailed information on each tax haven's economic, legal, political, cultural and geographical aspects, which must be considered if such an enterprise is to operate successfully.

Author : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 41,9 Mb
Release : 2012-12-06
Category : Business & Economics
ISBN : 9781461510710

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The International Taxation System by Andrew Lymer,John Hasseldine Pdf

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

Author : Colin Read,Greg N. Gregoriou
Publisher : Elsevier
Page : 391 pages
File Size : 52,9 Mb
Release : 2007-04-13
Category : Business & Economics
ISBN : 9780750683715

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International Taxation Handbook by Colin Read,Greg N. Gregoriou Pdf

Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 49,9 Mb
Release : 2021-05-14
Category : Law
ISBN : 9789403533643

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Exploring the Nexus Doctrine In International Tax Law by Ajit Kumar Singh Pdf

In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.

Author : Jinyan Li,Canadian Tax Foundation
Publisher : Unknown
Page : 655 pages
File Size : 54,6 Mb
Release : 2003
Category : Electronic commerce
ISBN : 0888081847

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International Taxation in the Age of Electronic Commerce by Jinyan Li,Canadian Tax Foundation Pdf

Author : Jacob A. Frenkel,Assaf Razin,Efraim Sadka
Publisher : MIT Press
Page : 268 pages
File Size : 55,6 Mb
Release : 1991
Category : Business & Economics
ISBN : 0262061430

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International Taxation in an Integrated World by Jacob A. Frenkel,Assaf Razin,Efraim Sadka Pdf

In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy.

Author : Anonim
Publisher : Unknown
Page : 12 pages
File Size : 43,9 Mb
Release : 1988
Category : Income tax
ISBN : MINN:31951D013914451

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Self-employment Tax by Anonim Pdf

Author : Felix I. Lessambo
Publisher : iUniverse
Page : 363 pages
File Size : 49,6 Mb
Release : 2009
Category : Business & Economics
ISBN : 9780595633074

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Taxation of International Business Transactions by Felix I. Lessambo Pdf

"With the increase in global trade now and in the future and the growth of multinational companies, an understanding of international tax law is imperative. In Taxation of International Business Transactions, author Dr. Felix Lessambo provides an overview of the sometimes challenging international tax law. Taxation of International Business Transactions provides sound understanding of foreign tax regimes and more. It is geared for those who want to mitigate, increase, and avoid tax audits in the areas of thin-capitalization, employee-secondment, transfer pricing, and limitations-on-benefits (LOB). Lessambo has tracked the ongoing issues of the most relevant aspects of international taxations and delivers suggestions in this edition. Lessambo, an international tax scholar and practitioner recognized for his keen analyses, provides firsthand expertise to help multinationals and international business managers to pursue business initiatives without the fear of unintended tax consequences. Taxation of International Business Transactions is an indispensable guide for tax and financial directors and those dealing with tax at a worldwide level."--Publisher's website.

Author : Vern Krishna
Publisher : Unknown
Page : 746 pages
File Size : 49,5 Mb
Release : 2012
Category : Income tax
ISBN : 1552212351

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Income Tax Law by Vern Krishna Pdf

This book is a comprehensive, up-to-date treatise on income tax law in Canada. The book introduces students and practitioners to income tax law in its broadest dimensions. It addresses the subject matter based on principles, policy, and practice. The objective is to explain what the law is, why it is the way it is, and how it works (or does not).