The History Of Double Taxation Conventions In The Pre Beps Era

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The History of Double Taxation Conventions in the Pre-BEPS Era

Anonim
The History of Double Taxation Conventions in the Pre BEPS Era Book PDF

Author : Anonim
Publisher : Unknown
Page : 1000 pages
File Size : 43,9 Mb
Release : 2021
Category : Electronic
ISBN : 9087226683

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The History of Double Taxation Conventions in the Pre-BEPS Era by Anonim Pdf

The design of international tax law cannot be described without recourse to its extensive history. By looking at the evolution of tax treaties, valuable insight is gained as regards the causes behind the most recent shift towards renewed international tax coordination in the framework of the BEPS Project. This book analyses how tax treaties have evolved, from the early days of the history of international taxation until the beginning of the BEPS era, by collecting the outcome of joint research on the development of international tax law. It consists of a wide range of papers bridging the existing gap between the history of international law, economic history and the history of international cooperation.0 0In this context, it also spells out the importance of the role of early institutions such as the International Chamber of Commerce and the League of Nations, as well as the International Fiscal Association and the OEEC/OECD, and helps to highlight their fundamental influence. The book is the result of the conference 'History of Double Taxation Conventions', which took place from 3-5 July 2008 in Rust/Neusiedler See. It consists of 30 contributions exploring the development of the tax treaty practices of 30 countries and, additionally, three cross-sectional contributions.

Tax Sovereignty in the BEPS Era

Sergio André Rocha,Allison Christians
Tax Sovereignty in the BEPS Era Book PDF

Author : Sergio André Rocha,Allison Christians
Publisher : Kluwer Law International B.V.
Page : 338 pages
File Size : 54,8 Mb
Release : 2016-04-24
Category : Law
ISBN : 9789041167088

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Tax Sovereignty in the BEPS Era by Sergio André Rocha,Allison Christians Pdf

The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

International Tax Policy and Double Tax Treaties

Kevin Holmes
International Tax Policy and Double Tax Treaties Book PDF

Author : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 44,6 Mb
Release : 2007
Category : Double taxation
ISBN : 9789087220235

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International Tax Policy and Double Tax Treaties by Kevin Holmes Pdf

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.

Multilateral Cooperation in Tax Law

Martin Klokar,Katharina Moldaschl
Multilateral Cooperation in Tax Law Book PDF

Author : Martin Klokar,Katharina Moldaschl
Publisher : Linde Verlag GmbH
Page : 357 pages
File Size : 53,6 Mb
Release : 2023-10-03
Category : Law
ISBN : 9783709412985

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Multilateral Cooperation in Tax Law by Martin Klokar,Katharina Moldaschl Pdf

An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021-23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.

Tax Transfer Pricing

Andrea Musselli
Tax Transfer Pricing Book PDF

Author : Andrea Musselli
Publisher : Gruppo 24 Ore
Page : 446 pages
File Size : 41,6 Mb
Release : 2022-09-15T00:00:00+02:00
Category : Business & Economics
ISBN : 9791254831540

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Tax Transfer Pricing by Andrea Musselli Pdf

The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.

International Tax at the Crossroads

Craig Elliffe
International Tax at the Crossroads Book PDF

Author : Craig Elliffe
Publisher : Edward Elgar Publishing
Page : 325 pages
File Size : 45,8 Mb
Release : 2023-12-11
Category : Law
ISBN : 9781800889026

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International Tax at the Crossroads by Craig Elliffe Pdf

In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.

A Journey Through European and International Taxation

Carla De Pietro,Cees Peters,Eric Kemmeren
A Journey Through European and International Taxation Book PDF

Author : Carla De Pietro,Cees Peters,Eric Kemmeren
Publisher : Kluwer Law International B.V.
Page : 625 pages
File Size : 55,5 Mb
Release : 2024-03-06
Category : Law
ISBN : 9789403532073

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A Journey Through European and International Taxation by Carla De Pietro,Cees Peters,Eric Kemmeren Pdf

To some extent, because of his overlapping careers in academia and politics, the renowned tax scholar Peter Essers is known for his influential insight that ‘the effects of taxation on the political balance of power, and vice versa, are always interlinked with other phenomena, such as wars, crises, religious developments and inequalities in society’. In this widely ranging festschrift, thirty-six prominent tax scholars from all across Europe examine the legacy of Peter Essers’ research interests, from the larger philosophical, political, and social factors driving tax history to the reality of the taxing State as experienced by taxpayers and tax officials. The book’s outstanding overview of the most relevant technical and policy aspects of European and international taxation includes deeply thoughtful chapters on such topics and issues as the following: developing sustainable corporate tax governance; tax whistleblowing; transfer pricing; balancing qualitative and quantitative approaches to tax research; necessity to reach something close to ‘equal treatment’ between the upper and lower social classes; consent and democracy; tax rebellions; tax evasion and tax avoidance; taxation of cross-border remote workers and their employers; mitigation of double taxation of income earned by entertainers and sportspersons; and the international tax treaty network. More than a homage to this scholar’s far-reaching contributions, this book is remarkable for the variety and academic rigour of the chapters. The understanding its authors provide of both the broad contours and the intricacies of European and international taxation will be of inestimable value to tax practitioners, policymakers, tax consultants, and academics, as well as interested researchers in economics, political science, and sociology.

Action Plan on Base Erosion and Profit Shifting

OECD
Action Plan on Base Erosion and Profit Shifting Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 44 pages
File Size : 54,9 Mb
Release : 2013-07-19
Category : Electronic
ISBN : 9789264202719

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Action Plan on Base Erosion and Profit Shifting by OECD Pdf

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

The Taxation of Pensions

Robert Holzmann,John Piggott
The Taxation of Pensions Book PDF

Author : Robert Holzmann,John Piggott
Publisher : MIT Press
Page : 521 pages
File Size : 47,6 Mb
Release : 2018-08-07
Category : Business & Economics
ISBN : 9780262347778

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The Taxation of Pensions by Robert Holzmann,John Piggott Pdf

Theoretical and policy perspectives on the taxation of pension, viewed in an international context. Policy makers and academic researchers have been preoccupied in recent decades with the design of pension schemes and effective pension system reform. Relatively little attention has been given to the taxation of pensions and, more broadly, the provision of retirement income. In this book, experts from a range of countries explore the interconnection. Their contributions are especially timely, given recent demographic and political developments including population aging that lengthens the time between contribution payment and benefit receipt, the mobility of capital and labor brought about by globalization, and the complexity of pension taxation within and between countries. In shedding light on these issues, the chapters document the various forms of taxation of pension systems; use economic theory to explain both qualitative and quantitative observations; and consider whether the observed interaction of taxation and pensions is efficient. Theoretical overviews are followed by rigorous analyses of pension taxation in specific countries, including Denmark, Sweden, Portugal, Australia, Germany, the United Kingdom, and the United States. Contributors Torben M. Andersen, Spencer Bastani, Hazel Bateman, Sören Blomquist, Axel Börsch-Supan, Jorge Miguel Bravo, Gary Burtless, Rafal Chomik, Helmuth Cremer, Carl Emmerson, Csaba Feher, Bernd Genser, Robert Holzmann, Paul Johnson, Alain Jousten, Christian Keuschnigg, Eric Koepcke, George Kudrna, Jukka Lassila, Luca Micheletto, Pierre Pestieau, John Piggott, Christopher Quinn, Tarmo Valkonen, Alan Woodland

Combating Tax Avoidance in the EU

José Manuel Almudí Cid,Jorge Ferreras Gutierrez,Pablo A. Hernández González-Barreda
Combating Tax Avoidance in the EU Book PDF

Author : José Manuel Almudí Cid,Jorge Ferreras Gutierrez,Pablo A. Hernández González-Barreda
Publisher : Kluwer Law International B.V.
Page : 656 pages
File Size : 45,7 Mb
Release : 2018-12-20
Category : Law
ISBN : 9789403501420

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Combating Tax Avoidance in the EU by José Manuel Almudí Cid,Jorge Ferreras Gutierrez,Pablo A. Hernández González-Barreda Pdf

Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS

OECD
OECD G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation Interim Report 2018 Inclusive Framework on BEPS Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 216 pages
File Size : 51,7 Mb
Release : 2018-03-16
Category : Electronic
ISBN : 9789264293083

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OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS by OECD Pdf

This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

The Future of Multilateralism

Madeleine O. Hosli,Taylor Garrett,Sonja Niedecken,Nicolas Verbeek
The Future of Multilateralism Book PDF

Author : Madeleine O. Hosli,Taylor Garrett,Sonja Niedecken,Nicolas Verbeek
Publisher : Rowman & Littlefield
Page : 329 pages
File Size : 49,6 Mb
Release : 2021-07-29
Category : Political Science
ISBN : 9781538155295

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The Future of Multilateralism by Madeleine O. Hosli,Taylor Garrett,Sonja Niedecken,Nicolas Verbeek Pdf

The Future of Multilateralism addresses current challenges and future perspectives of international and regional organizations. It aims to uncover how stable the foundations of global cooperation really are, particularly in the light of the latest unilateral and protectionist practices of international players and challenges related to COVID-19. The post–World War II global order was built on the foundations of multilateral cooperation. The establishment of international institutions is aimed at avoiding another widespread collision like the two World Wars and to ensure peace and prosperity. Hence, the multilateral system was viewed as an effective mechanism in dealing and resolving various challenges at an international or a regional level. Given the effects of COVID-19 on the global, regional, state, and individual levels are so recent, very little research has been conducted to understand the challenges many multilateral institutions are facing due to the pandemic. This book uncovers the future of such organizations and prospects for the multilateral system, of which they constitute the building blocks, in view of recent trends and developments.