International Company Taxation In The Era Of Information And Communication Technologies

Author : Anne Schäfer
Publisher : Springer Science & Business Media
Page : 247 pages
File Size : 43,9 Mb
Release : 2007-12-18
Category : Business & Economics
ISBN : 9783835091382

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International Company Taxation in the Era of Information and Communication Technologies by Anne Schäfer Pdf

Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.

Author : Michael Lang,Peter Melz,Eleonor Kristoffersson,Thomas Ecker
Publisher : IBFD
Page : 1341 pages
File Size : 50,8 Mb
Release : 2009
Category : Direct taxation
ISBN : 9789087220600

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Value Added Tax and Direct Taxation by Michael Lang,Peter Melz,Eleonor Kristoffersson,Thomas Ecker Pdf

This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.

Author : Ina Kerschner,Maryte Somare
Publisher : Linde Verlag GmbH
Page : 488 pages
File Size : 53,6 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 : Sven Hentschel
Publisher : Springer Nature
Page : 521 pages
File Size : 47,8 Mb
Release : 2021-06-26
Category : Law
ISBN : 9783658340001

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The Taxation of Permanent Establishments by Sven Hentschel Pdf

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.

Author : D.S. Smit
Publisher : Kluwer Law International B.V.
Page : 822 pages
File Size : 42,5 Mb
Release : 2012-06-01
Category : Law
ISBN : 9789041140746

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EU Freedoms, Non-EU Countries and Company Taxation by D.S. Smit Pdf

In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.

Author : John G. Head,Richard E. Krever
Publisher : Kluwer Law International B.V.
Page : 578 pages
File Size : 55,7 Mb
Release : 2009-01-01
Category : Law
ISBN : 9789041128294

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Tax Reform in the 21st Century by John G. Head,Richard E. Krever Pdf

No government can be sustained without the ability to tax its citizens. The question then arises how can a nation do so in a way that's fair and equitable to taxpayers while simultaneously promoting economic growth and providing the state with the funds it needs to adequately address the needs of its citizens? This insightful work, featuring contributions from a stellar array of international tax experts and economists, addresses the crucial, relevant issues which developed countries will confront in the early decades of the 21st century: The pursuit of tax reform. Personal tax base: income or consumption? Tax rate scale: equity and efficiency aspects. Business tax reform: structural and design issues. Interjurisdictional issues. Controlling tax avoidance.

Author : Carsten Wendt
Publisher : Springer Science & Business Media
Page : 231 pages
File Size : 43,7 Mb
Release : 2009-04-16
Category : Business & Economics
ISBN : 9783834981936

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A Common Tax Base for Multinational Enterprises in the European Union by Carsten Wendt Pdf

Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.

Author : Sven-Eric Bärsch
Publisher : Springer Science & Business Media
Page : 406 pages
File Size : 47,8 Mb
Release : 2012-12-13
Category : Business & Economics
ISBN : 9783642324574

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Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context by Sven-Eric Bärsch Pdf

Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.

Author : Zheng Sophia Tang
Publisher : Bloomsbury Publishing
Page : 336 pages
File Size : 44,8 Mb
Release : 2015-10-22
Category : Law
ISBN : 9781782259305

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Electronic Consumer Contracts in the Conflict of Laws by Zheng Sophia Tang Pdf

The second edition of this highly recommended work addresses the interaction between conflict of laws, dispute resolution, electronic commerce and consumer contracts. In addition it identifies specific difficulties that conflicts lawyers and consumer lawyers encounter in electronic commerce and proposes original approaches to balance the conflict of interest between consumers' access to justice and business efficiency. The European Union has played a leading role in this area of law and its initiatives are fully explored. It pays particular attention to the most recent development in collective redress and alternative/online dispute resolution. By adopting multiple research methods, including a comparative study of the EU and US approach; historical analysis of protective conflict of laws; doctrinal analysis of legal provisions and economic analysis of law, it provides the most comprehensive examination of frameworks in cross-border consumer contracts.

Author : OECD
Publisher : OECD Publishing
Page : 288 pages
File Size : 50,9 Mb
Release : 2015-10-05
Category : Electronic
ISBN : 9789264241046

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OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy, Action 1 - 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 1.

Author : Ms.Thornton Matheson,Patrick Petit
Publisher : International Monetary Fund
Page : 42 pages
File Size : 52,9 Mb
Release : 2017-11-15
Category : Business & Economics
ISBN : 9781484324981

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Taxing Telecommunications in Developing Countries by Ms.Thornton Matheson,Patrick Petit Pdf

Developing countries apply numerous sector-specific taxes to telecommunications, whose buoyant revenues and formal enterprises provide a convenient “tax handle”. This paper explores whether there is an economic rationale for sector-specific taxes on telecommunications and, if so, what form they should take to balance the competing goals of promoting connectivity and mobilizing revenues. A survey of the literature finds that limited telecoms competition likely creates rents that could efficiently be taxed. We propose a “pecking order” of sector-specific taxes that could be levied in addition to standard income and value-added taxes, based on capturing rents and minimizing distortions. Taxes that target possible economic rents or profits are preferable, but their administrative challenges may necessitate reliance on service excises at the cost of higher consumer prices and lower connectivity. Taxes on capital inputs and consumer access, which distort production and restrict network access, should be avoided; so should tax incentives, which are not needed to attract foreign capital to tap a local market.

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 44,7 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827

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U.S. Tax Guide for Aliens by Anonim Pdf

Author : United Nations Conference on Trade and Development
Publisher : United Nations Publications
Page : 68 pages
File Size : 50,5 Mb
Release : 2005
Category : Political Science
ISBN : UOM:39015064129870

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Taxation and Technology Transfer by United Nations Conference on Trade and Development Pdf

"The report gives an overview of the impact of taxation in developed and developing countries on the transfer of technology and seeks to shed light on the formulation of tax policies that could facilitate technology transfer"--Page iii.

Author : National Intelligence Council
Publisher : Cosimo Reports
Page : 158 pages
File Size : 42,7 Mb
Release : 2021-03
Category : Electronic
ISBN : 1646794974

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Global Trends 2040 by National Intelligence Council Pdf

"The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.

Author : Piaggesi, Danilo,Sund, Kristian,Castelnovo, Walter
Publisher : IGI Global
Page : 564 pages
File Size : 52,7 Mb
Release : 2011-04-30
Category : Business & Economics
ISBN : 9781609604905

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Global Strategy and Practice of E-Governance: Examples from Around the World by Piaggesi, Danilo,Sund, Kristian,Castelnovo, Walter Pdf

Over the past decade, there has been continual development and renewal of strategies and practices surrounding e-governance. Governments around the world have embraced new information and communication technologies to increase the efficiency of internal processes, deliver better and more integrated services to citizens and businesses, invite citizen and stakeholder participation in planning decisions, improve communication, and sometimes even enhance democratic processes. Global Strategy and Practice of E-Governance: Examples from Around the World provides readers with an overview of relevant strategy and policy-level theoretical frameworks and examples, as well as up-to-date implementations from around the world. This book offers valuable insights into best practices, as well as some of the issues and challenges surrounding the governance of and with information and communication technologies in a globalized, knowledge-based world.