International Taxation Of Energy Production And Distribution

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 546 pages
File Size : 52,9 Mb
Release : 2018-04-20
Category : Law
ISBN : 9789041191205

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International Taxation of Energy Production and Distribution by John Abrahamson Pdf

Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.

Author : Anonim
Publisher : Unknown
Page : 364 pages
File Size : 47,6 Mb
Release : 1976
Category : Energy policy
ISBN : STANFORD:36105211338129

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Energy Fact Book by Anonim Pdf

Author : Mr. Benedict J. Clements,David Coady,Ms. Stefania Fabrizio,Mr. Sanjeev Gupta,Mr. Trevor Serge Coleridge Alleyne,Mr. Carlo A. Sdralevich
Publisher : International Monetary Fund
Page : 194 pages
File Size : 44,5 Mb
Release : 2013-09-13
Category : Business & Economics
ISBN : 9781484339169

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Energy Subsidy Reform by Mr. Benedict J. Clements,David Coady,Ms. Stefania Fabrizio,Mr. Sanjeev Gupta,Mr. Trevor Serge Coleridge Alleyne,Mr. Carlo A. Sdralevich Pdf

Energy subsidies have wide-ranging economic consequences. Although they are aimed at protecting consumers, subsidies aggravate fiscal imbalances, crowd out priority public spending, and depress private investment, including in the energy sector. Subsidies also distort resource allocation by encouraging excessive energy consumption, artificially promoting capital-intensive industries, reducing incentives for investment in renewable energy, and accelerating the depletion of natural resources. Most subsidy benefits are captured by higher-income households, reinforcing inequality. Even future generations are affected through the damaging effects of increased energy consumption on global warming. This book provides (1) the most comprehensive estimates of energy subsidies currently available for 176 countries and (2) an analysis of “how to do” energy subsidy reform, drawing on insights from 22 country case studies undertaken by the IMF staff and analyses carried out by other institutions.

Author : OECD
Publisher : OECD Publishing
Page : 105 pages
File Size : 46,9 Mb
Release : 2019-10-15
Category : Electronic
ISBN : 9789264627444

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Taxing Energy Use 2019 Using Taxes for Climate Action by OECD Pdf

Taxing Energy Use (TEU) 2019 presents a snapshot of where countries stand in deploying energy and carbon taxes, tracks progress made, and makes actionable recommendations on how governments could do better. The report contains new and original data on energy and carbon taxes in OECD and G20 countries, and in international aviation and maritime transport.

Author : Organisation for Economic Co-operation and Development
Publisher : Organization for Economic Co-Operation & Development
Page : 260 pages
File Size : 46,7 Mb
Release : 2013-02-19
Category : Energy consumption
ISBN : UCR:31210023798612

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Taxing Energy Use by Organisation for Economic Co-operation and Development Pdf

Taxation is one of the most important government policies affecting energy use and therefore the environmental problems (such as greenhouse gas emissions and air pollution) to which various forms of energy use can give rise. This report provides the first systematic comparative analysis of the structure and level of energy taxes in all OECD countries. It presents effective tax rates on energy use in terms of both energy content and carbon emissions, together with detailed graphical profiles of both the structure of energy use and energy taxes in each country. It is a data-rich tool that will help policy makers and analysts to evaluate the role and impact of current energy tax settings and to plan potential reforms. The report offers comparative statistics on and graphical profiles of all 34 OECD countries: Australia, Austria, Belgium, Canada, Chile, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, United Kingdom and United States.

Author : Mrs.Poonam Gupta,Mr.Walter Mahler
Publisher : International Monetary Fund
Page : 58 pages
File Size : 42,5 Mb
Release : 1994-03-01
Category : Business & Economics
ISBN : 9781451979756

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Taxation of Petroleum Products by Mrs.Poonam Gupta,Mr.Walter Mahler Pdf

The domestic taxation of petroleum products is an important source of revenue in most countries. However, there is a wide variation of tax rates on petroleum products across countries, which cannot be explained by economic theory alone. This paper surveys different considerations advanced for taxing petroleum and presents petroleum tax rate data in 120 countries. It concludes that a significant reduction in the present extremely wide variation in petroleum prices and tax rates appears warranted.

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 82 pages
File Size : 55,8 Mb
Release : 2012-08-16
Category : Business & Economics
ISBN : 9781498340069

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Fiscal Regimes for Extractive Industries—Design and Implementation by International Monetary Fund. Fiscal Affairs Dept. Pdf

Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Author : International Renewable Energy Agency IRENA
Publisher : International Renewable Energy Agency (IRENA)
Page : 96 pages
File Size : 45,6 Mb
Release : 2019-06-01
Category : Technology & Engineering
ISBN : 9789292602666

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Renewable Energy and Jobs – Annual Review 2020 by International Renewable Energy Agency IRENA Pdf

The sixth edition of the series highlights employment trends in renewables worldwide, noting increasing diversification of the supply chain.

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 448 pages
File Size : 43,5 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 : OECD
Publisher : OECD Publishing
Page : 133 pages
File Size : 48,5 Mb
Release : 2001-10-05
Category : Electronic
ISBN : 9264193650

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Environmentally Related Taxes in OECD Countries Issues and Strategies by OECD Pdf

This report analyses current use of environmentally related taxes in OECD Member countries. Focus is given to their environmental effectiveness. The report identifies obstacles to a broader use of such taxes -- in particular the fear of loss of sectoral competitiveness -- and ways to overcome them.

Author : Baoping Shang
Publisher : International Monetary Fund
Page : 32 pages
File Size : 44,5 Mb
Release : 2021-06-25
Category : Business & Economics
ISBN : 9781513573397

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The Poverty and Distributional Impacts of Carbon Pricing: Channels and Policy Implications by Baoping Shang Pdf

Addressing the poverty and distributional impacts of carbon pricing reforms is critical for the success of ambitious actions in the fight against climate change. This paper uses a simple framework to systematically review the channels through which carbon pricing can potentially affect poverty and inequality. It finds that the channels differ in important ways along several dimensions. The paper also identifies several key gaps in the current literature and discusses some considerations on how policy designs could take into account the attributes of the channels in mitigating the impacts of carbon pricing reforms on households.

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 40,5 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 : Oliver Lah
Publisher : Elsevier
Page : 310 pages
File Size : 54,8 Mb
Release : 2018-12-03
Category : Law
ISBN : 9780128148983

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Sustainable Urban Mobility Pathways by Oliver Lah Pdf

Sustainable Urban Mobility Pathways examines how sustainable urban mobility solutions contribute to achieving worldwide sustainable development and global climate change targets, while also identifying barriers to implementation and strategies to overcome them. Building on city-to-city cooperation experiences in Europe, Asia, Africa and Latin America, the book examines key challenges in the context of the Paris Agreement, UN Sustainable Development Goals and the New Urban Agenda, including policies needed to achieve a sustainable, low-carbon pathway for transport and how an integrated policy strategy is designed to provide a basis for political coalitions. The book explores which institutional framework creates sufficient political stability and continuity to foster the take-up of and long-term support for sustainable transport strategies. The linkages of climate change and wider sustainable development objectives are covered, including success stories, best practices, and quantitative analysis for key emerging economies in public transport, walking, cycling, freight and logistics, vehicle technology and fuels, urban planning and integration, and national framework policies. Provides a holistic view of sustainable urban transport, focusing on policy-making processes, the role of institutions and successes and pitfalls Delivers practical insights drawn from the experiences of actual city-to-city cooperation and on-the-ground policy work Explores options for the integration of policy objectives and institutional structures that form coalitions for the implementation of sustainable urban mobility solutions Describes the policy, institutional, political, and socio-economic aspects in cities in five emerging economies: Brazil, China, India, Mexico, and Turkey

Author : Aleksandra Bal
Publisher : Kluwer Law International B.V.
Page : 314 pages
File Size : 46,9 Mb
Release : 2018-11-29
Category : Law
ISBN : 9789403501048

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Taxation, Virtual Currency and Blockchain by Aleksandra Bal Pdf

The emergence of convertible decentralized virtual currency schemes confronts tax authorities with unprecedented questions, among them are the status of virtual currency for tax purposes, which virtual transactions may bene?t from a VAT exemption and determining the most optimal method of tax regulation. This ?rst book-length treatment of this major current topic provides an in-depth and comprehensive analysis of the tax implications of virtual currency transactions. Seeking to ascertain whether virtual currency requires additional regulation or whether the law as it stands is adequate to administer its usage, the analysis not only thoroughly explains the nature of the underlying blockchain technology and its regulatory and judicial treatment so far but also identi?es best practices for virtual currency transactions and makes recommendations for the improvement of the existing tax systems. Among the aspects of the phenomenon covered are the following: – particular aspects of virtual currency use such as smart contracts and initial coin offerings; – comparative review of income tax consequences of virtual currency transactions in Germany, the Netherlands, the United Kingdom and the United States; – VAT/sales tax treatment of transactions involving virtual currency in the European Union and the United States; – methodology for creating an effective regulatory framework for the taxation of virtual currency; and – the future of blockchain. The book has three parts and an annex that describes tax regulations, administrative rulings and court decisions concerning virtual currency in twenty countries. In its in-depth analysis of tax implications of virtual currency transactions in major economies, detailed overview of recent tax developments that affect virtual currency transactions and evaluation of tax policies related to virtual currencies, this book has no peers. Especially in view of the OECD's examination of the tax challenges presented by the digital economy as part of its base erosion and pro?t shifting (BEPS) project, this clear and comprehensive explanation of the functioning of virtual currency and blockchain technology will be welcomed by tax administration of?cials and by persons mining and transacting in virtual currencies needing to know their compliance obligations.

Author : Leopoldo Parada
Publisher : Kluwer Law International B.V.
Page : 531 pages
File Size : 48,7 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.