Principles Of International Taxation

Author : Lynne Oats
Publisher : Bloomsbury Publishing
Page : 773 pages
File Size : 54,9 Mb
Release : 2021-09-30
Category : Business & Economics
ISBN : 9781526519566

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Principles of International Taxation by Lynne Oats Pdf

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.

Author : Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 573 pages
File Size : 51,9 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 : Angharad Miller,Lynne Oats
Publisher : A&C Black
Page : 687 pages
File Size : 44,6 Mb
Release : 2012-01-01
Category : Law
ISBN : 9781847668790

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Principles of International Taxation by Angharad Miller,Lynne Oats Pdf

This superb book will guide the reader through the key issues and practical aspects of international tax practice. It demonstrates how different global tax systems interact and how to prevent paying more tax than necessary. The basic principles of each aspect of international taxation are outlined and then examined in greater depth and detail. This updated third edition includes coverage of both UK and EU legislation and regulation, as well as the key cases and rulings. Complicated double taxation concepts are clearly illustrated with examples and diagrams to help the reader quickly understand how they'll apply in practice. Examples of policies adopted in other countries are included, along with specialist commentary and guidance.

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 41,9 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 : Adrian Ogley
Publisher : International Information Services Incorporated
Page : 186 pages
File Size : 45,6 Mb
Release : 1993
Category : Business & Economics
ISBN : 095204420X

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The Principles of International Tax by Adrian Ogley Pdf

This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.

Author : Mark Brabazon
Publisher : Cambridge University Press
Page : 417 pages
File Size : 42,9 Mb
Release : 2019-05-02
Category : Law
ISBN : 9781108492256

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International Taxation of Trust Income by Mark Brabazon Pdf

This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

Author : Lynne Oats,Emer Mulligan
Publisher : Unknown
Page : 128 pages
File Size : 46,9 Mb
Release : 2019
Category : Electronic
ISBN : 1526510405

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Principles of International Taxation by Lynne Oats,Emer Mulligan Pdf

Author : Jacob A. Frenkel,Assaf Razin,Efraim Sadka
Publisher : MIT Press
Page : 268 pages
File Size : 40,7 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 : Roy Rohatgi
Publisher : Richmond Law & Ted Limited
Page : 467 pages
File Size : 40,8 Mb
Release : 2005-01-01
Category : Business & Economics
ISBN : 1904501575

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Basic International Taxation by Roy Rohatgi Pdf

Provides a comprehensive overview of the basic principles of international taxation and considers these in the context of practical planning guidance. This book presents an analysis of the practical application of these principles, supported by a review of international tax practices by leading professionals in over sixty jurisdictions worldwide.

Author : Peter Hongler
Publisher : Oxford University Press
Page : 289 pages
File Size : 48,8 Mb
Release : 2021
Category : Law
ISBN : 9780192898715

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International Law of Taxation by Peter Hongler Pdf

In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.

Author : Xavier Oberson,Howard R. Hull
Publisher : IBFD
Page : 457 pages
File Size : 54,8 Mb
Release : 2011
Category : Double taxation
ISBN : 9789087220983

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Switzerland in International Tax Law by Xavier Oberson,Howard R. Hull Pdf

"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).

Author : Ulrich Schreiber
Publisher : Springer Science & Business Media
Page : 179 pages
File Size : 46,5 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 : Asif H. Qureshi,Ajay Kumar
Publisher : Kluwer Law International B.V.
Page : 963 pages
File Size : 52,7 Mb
Release : 2019-05-22
Category : Law
ISBN : 9789041184771

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The Public International Law of Taxation by Asif H. Qureshi,Ajay Kumar Pdf

The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.

Author : Jane Frecknall-Hughes
Publisher : Routledge
Page : 148 pages
File Size : 40,6 Mb
Release : 2014-10-03
Category : Business & Economics
ISBN : 9781135085759

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The Theory, Principles and Management of Taxation by Jane Frecknall-Hughes Pdf

There are many practical textbooks explaining how taxation is applied and calculated but few ever deal thoroughly with the theory behind the practice. This book concisely addresses the principles and theories behind taxation in an accessible and internationally relevant way. It encourages readers to think through and develop an understanding of why taxation is imposed, the different means by which it is imposed and the nature of the problems inherent in this imposition. It addresses background issues, fundamental principles and emerging topics such as: the philosophy and history of taxation; types of taxation; and international issues, including double taxation treaties, residence and transfer prices. This text is essential reading for students of taxation and provides a valuable introduction for students of business, finance and accounting.

Author : Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 441 pages
File Size : 54,5 Mb
Release : 2006
Category : Income tax
ISBN : 0433392193

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