Taxation Of Investment Funds In The European Union

Author : Tomi Viitala
Publisher : IBFD
Page : 427 pages
File Size : 54,7 Mb
Release : 2005
Category : Capital gains tax
ISBN : 9789076078755

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Taxation of Investment Funds in the European Union by Tomi Viitala Pdf

The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.

Author : Tomi Viitala
Publisher : Unknown
Page : 382 pages
File Size : 43,8 Mb
Release : 2004
Category : Electronic
ISBN : 9515642086

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Tax Treatment of Investment Funds and Their Investors Within the European Union by Tomi Viitala Pdf

Author : Werner Haslehner
Publisher : Kluwer Law International B.V.
Page : 330 pages
File Size : 45,9 Mb
Release : 2017-04-24
Category : Law
ISBN : 9789041196798

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Investment Fund Taxation by Werner Haslehner Pdf

The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.

Author : Anonim
Publisher : Unknown
Page : 279 pages
File Size : 43,5 Mb
Release : 1999
Category : Equality
ISBN : LCCN:99016460

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The Principle of Equality in European Taxation by Anonim Pdf

Author : Richard Snoeij
Publisher : Kluwer Law International B.V.
Page : 378 pages
File Size : 53,9 Mb
Release : 2018-04-18
Category : Law
ISBN : 9789041194336

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International Tax Aspects of Sovereign Wealth Investors by Richard Snoeij Pdf

An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.

Author : Christiana H. J. I. Panayi
Publisher : Cambridge University Press
Page : 397 pages
File Size : 53,7 Mb
Release : 2021-06-17
Category : Law
ISBN : 9781108983488

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European Union Corporate Tax Law by Christiana H. J. I. Panayi Pdf

How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies, and permanent establishments. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.

Author : Joann Martens-Weiner
Publisher : Springer Science & Business Media
Page : 127 pages
File Size : 51,5 Mb
Release : 2006-03-14
Category : Business & Economics
ISBN : 9780387294872

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Company Tax Reform in the European Union by Joann Martens-Weiner Pdf

Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.

Author : Salvador Trinxet Llorca
Publisher : Asset Protection Publishing
Page : 160 pages
File Size : 52,5 Mb
Release : 2010
Category : Electronic
ISBN : 9780956776600

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European Union Direct Taxes by Salvador Trinxet Llorca Pdf

Author : Christiana HJI Panayi,Werner Haslehner,Edoardo Traversa
Publisher : Edward Elgar Publishing
Page : 672 pages
File Size : 48,6 Mb
Release : 2020-01-31
Category : Law
ISBN : 9781788110846

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Research Handbook on European Union Taxation Law by Christiana HJI Panayi,Werner Haslehner,Edoardo Traversa Pdf

Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.

Author : Carlos Pinto
Publisher : Unknown
Page : 128 pages
File Size : 52,8 Mb
Release : 2003
Category : Electronic
ISBN : 904119679X

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Tax Competition and EU Law by Carlos Pinto Pdf

Author : Alex Easson
Publisher : Springer
Page : 232 pages
File Size : 41,9 Mb
Release : 1999-08-24
Category : Business & Economics
ISBN : STANFORD:36105060443392

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Taxation of Foreign Direct Investment:An Introduction by Alex Easson Pdf

This book describes the many different ways in which national tax rules and international tax principles affect foreign direct investment decisions, and examines their impact on the establishment and operation of foreign-invested projects. It focuses on tax provisions in both host and home countries, and looks at the role of tax treaties, the methods of relieving double taxation and of countering tax avoidance.

Author : Dennis Manolito Weber
Publisher : Unknown
Page : 360 pages
File Size : 42,7 Mb
Release : 2013
Category : Income tax--Law and legislation--European Union countries
ISBN : 9087222076

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EU Income Tax Law: Issues for the Years Ahead by Dennis Manolito Weber Pdf

Author : Gloria Teixeira
Publisher : Wiley
Page : 570 pages
File Size : 44,8 Mb
Release : 1999-04-22
Category : Business & Economics
ISBN : 0471951579

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Business Taxation in the European Union by Gloria Teixeira Pdf

Written on a country-by-country basis, this book offers an analysis of the tax consequences and practical necessities of foreign investment in European Union countries: setting up new companies, merging with local companies, establishing branches/subsidiaries/permanent establishments, purchasing shares in domestic companies and equity versus debt finance. Discusses the corporate tax system of each country, the rules on the taxation of the parent-subsidiary relationship and the impact of double tax treaties.

Author : Christiana HJI Panayi
Publisher : Unknown
Page : 128 pages
File Size : 40,5 Mb
Release : 2013
Category : Corporations
ISBN : 1107357489

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European Union Corporate Tax Law by Christiana HJI Panayi Pdf

"How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted"--

Author : Fiona Beveridge
Publisher : Manchester University Press
Page : 0 pages
File Size : 41,6 Mb
Release : 2000
Category : Investments, Foreign
ISBN : 0719043093

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The Treatment and Taxation of Foreign Investment Under International Law by Fiona Beveridge Pdf

This is an examination of key issues concerning the treatment of foreign investment and the taxation of investors. It looks at some of the challenges which globalization has thrown up for the international community from a legal perspective and sets recent developments alongside more traditional approaches. Particular attention is paid to the needs and aspirations of developing countries and the implications for them of the current free trade orthodoxy. After outlining the established framework of laws concerning investment protection and taxation, the author looks at experiences in the European Union and the North Atlantic Free Trade Agreement and at a range of recent disputes and legal developments to assess whether international legal regimes are responding adequately to meet the needs of states and investors alike. Recent OECD initiatives on taxation and the aborted Multilateral Agreement on Investment negotiations are examined in conjunction with the relevant provisions of the World Trade Organization Agreements.