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Author : Tsilly Dagan
Publisher : Cambridge University Press
Page : 263 pages
File Size : 47,6 Mb
Release : 2017-12-14
Category : Business & Economics
ISBN : 9781107112100
Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.
Author : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 53,5 Mb
Release : 2007
Category : Double taxation
ISBN : 9789087220235
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Author : Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 48,5 Mb
Release : 2019-01-14
Category : Law
ISBN : 9789403501727
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Author : Reuven S. Avi-Yonah
Publisher : Edward Elgar Publishing
Page : 169 pages
File Size : 54,8 Mb
Release : 2015-02-27
Category : Law
ISBN : 9781781952320
Advanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax. Systems of taxation deviate between jurisdictio
Author : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 55,8 Mb
Release : 2012-12-06
Category : Business & Economics
ISBN : 9781461510710
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 : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 40,6 Mb
Release : 2021-05-14
Category : Law
ISBN : 9789403533643
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,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 573 pages
File Size : 52,7 Mb
Release : 2018
Category : Income tax
ISBN : 0433495642
Author : Martin Hearson
Publisher : Cornell Studies in Money
Page : 246 pages
File Size : 45,9 Mb
Release : 2021
Category : Developed countries
ISBN : 1501755986
The problem with tax treaties -- A history of developing countries in (and out of) global tax governance -- Turning the tables: the competition discourse and north-south relations -- OECD knows best: the expert view of tax treaties -- The United Kingdom -- Zambia -- Vietnam and Cambodia -- Historical legacies in a rapidly changing world.
Author : National Research Council,Board on Science, Technology, and Economic Policy
Publisher : National Academies Press
Page : 169 pages
File Size : 50,7 Mb
Release : 1998-02-05
Category : Political Science
ISBN : 9780309063685
The growing integration of world markets for capital and goods, coupled with the rise of instantaneous worldwide communication, has made identification of corporations as "American," "Dutch," or "Japanese" extremely difficult. Yet tax treatment does depend of where a firm is chartered. And, as Borderline Case documents, there is little doubt that tax rules for firms doing business in several nationsâ€"firms that account for more than three-quarters of corporate R&D spending in the United Statesâ€"have substantial effects on corporate decisionmaking and, ultimately, U.S. competitiveness. This book explores the impact of the U.S. tax code and its incentives on the international activities of U.S.- and foreign-based firms: basic research outlays, expenditures on product and process development, and plant and equipment investment. The authors include industry experts from large multinational firms in technology and pharmaceuticals, academic researchers who have explored the quantitative impact of tax provisions on R&D, and tax policy analysts who have examined international tax rules in the broader context of tax reform. These experts look at how corporate investment and R&D are shaped by specific tax provisions, such as the definition of taxable income, relative tax burdens on domestic and foreign business, taxation of earnings repatriated to the United States, deductibility of expenses of worldwide operations, and U.S. corporate taxes relative to other countries. The volume explores prescriptions and prospects for tax reform and reviews major reform proposals and their implications for the behavior of multinational business.
Author : Brigitte Alepin,Lyne Latulippe,Louise Otis
Publisher : Kluwer Law International B.V.
Page : 301 pages
File Size : 41,7 Mb
Release : 2021-11-25
Category : Law
ISBN : 9789403537603
Series on International Taxation #81 The tax landscape today looks dramatically different from how it appeared even a generation ago. Ongoing sweeping changes in information technologies, massive economic downturns, unforeseen catastrophes such as the global pandemic that hit the world in 2020, and ever more sophisticated methods of tax evasion and avoidance are only some of the factors that have perplexed and even confounded tax authorities. This important book provides a comprehensive overview of the global tax challenges confronting tax policy today, with insightful contributions by both well-known tax experts and fresh new voices in the field. The authors address such critical issues as the following: international tax reform initiatives; effects of climate change; tax justice in times of crisis; international tax cooperation; taxing multinationals; role of tax havens; participation and collaboration of developing countries; the growing presence of artificial intelligence and robots; prospects for a green economic recovery; and tax ethics and social inclusiveness. The contributions originated with the groundbreaking tax summit TaxCOOP2020, held online at the peak of the Covid-19 pandemic in October 2020. At a time when tax policy seems poised at the dawn of a fundamental transformation, this inestimable volume will be welcomed by tax practitioners and academics, concerned government officials, businesspeople, international organizations, and non-governmental organizations (NGOs), all of whom will here have access to a variety of points of view and innovative approaches to the future direction of taxation.
Author : T. Rixen
Publisher : Springer
Page : 249 pages
File Size : 40,7 Mb
Release : 2008-11-03
Category : Political Science
ISBN : 9780230582651
Covering the period from the 1920s, when international tax policy was solely about avoiding double taxation, to the present era of international tax competition, Rixen investigates the fate of 'the power to tax' in an era of globalization, illustrating that tax sovereignty is both shaped and constrained by an international tax regime.
Author : Xavier Oberson,Howard R. Hull
Publisher : Unknown
Page : 280 pages
File Size : 48,6 Mb
Release : 1996
Category : Double taxation
ISBN : STANFORD:36105062291526
An introduction to Swiss international tax law, its characteristics and guiding principles. Particular attention is paid to the special tax relief granted to Swiss resident individuals and corporations, as well as to the complex rules for the avoidance of treaty abuse. The authors also discuss the Swiss case law developed for the avoidance of intercantonal double taxation, the tax credit and the Swiss approaches both to transfer pricing and the implementation of mutual agreement procedures.
Author : Luzius U. Cavelti
Publisher : Stämpfli Verlag
Page : 338 pages
File Size : 49,5 Mb
Release : 2016-10-27
Category : Law
ISBN : 9783727259708
Why is international cooperation on taxation so difficult to achieve? The problems in international taxation arise from a sovereignty conflict between the country in which the income originates (source country) and the country in which the recipient of the income resides (residence country). This book explores the equally valid sovereign tax claims of source and of residence countries and highlights the incompatibility of these concurrent tax claims. The resulting incoherence between source and residence countries distorts taxation of cross-border income to a point where it not only creates discriminations but challenges the fundamental principles of international taxation in itself. This is an essential dilemma of international tax policy. And yet, given the profound role the power to tax plays in exercising sovereignty, are governments able, or even willing, to eliminate this essential dilemma?
Author : Martin Feldstein,James R. Hines,R. Glenn Hubbard
Publisher : University of Chicago Press
Page : 338 pages
File Size : 47,9 Mb
Release : 2007-12-01
Category : Business & Economics
ISBN : 9780226241876
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
Author : Allison Christians,Laurens van Apeldoorn
Publisher : Oxford University Press
Page : 209 pages
File Size : 55,6 Mb
Release : 2021
Category : Tax planning
ISBN : 9780192848673
The way that nation states design their tax systems impacts the sharing of resources and wealth within and across societies. To date, wealthy countries have made tax policy design and coordination choices which allow them to claim more than they are justifiably entitled to from the global economy. In Tax Cooperation in an Unjust World, Allison Christians and Laurens van Apeldoorn show how this presently accepted reality both facilitates and feeds off continued human suffering, and therefore violates conceptions of international distributive justice. They examine two principles that govern tax cooperation across states, and explain how the current international tax order impedes their realization. They then show how states could work toward fulfilling the principles and building a fairer international tax system via incremental yet effective adaptation of key international tax norms and rules.
