The Principles Of International Tax

Author : Lynne Oats
Publisher : Bloomsbury Publishing
Page : 773 pages
File Size : 51,7 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 : 40,5 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 : 46,5 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 : Roy Rohatgi
Publisher : Richmond Law & Ted Limited
Page : 467 pages
File Size : 51,5 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 : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 41,6 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 : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 50,6 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.

Author : Reuven S. Avi-Yonah
Publisher : Edward Elgar Publishing
Page : 231 pages
File Size : 55,7 Mb
Release : 2019
Category : Double taxation
ISBN : 9781788978491

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Advanced Introduction to International Tax Law by Reuven S. Avi-Yonah Pdf

This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.

Author : Paul R. McDaniel,James R. Repetti,Diane M. Ring
Publisher : Unknown
Page : 0 pages
File Size : 52,8 Mb
Release : 2014
Category : Aliens
ISBN : 9041136568

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Introduction to United States International Taxation by Paul R. McDaniel,James R. Repetti,Diane M. Ring Pdf

This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. It sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad.

Author : Lynne Oats,Emer Mulligan
Publisher : Unknown
Page : 128 pages
File Size : 42,8 Mb
Release : 2019
Category : Electronic
ISBN : 1526510405

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Principles of International Taxation by Lynne Oats,Emer Mulligan Pdf

Author : Roy Saunders
Publisher : First Stone Publishing
Page : 328 pages
File Size : 48,5 Mb
Release : 2005
Category : Tax planning
ISBN : 1903333229

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The Principles of International Tax Planning by Roy Saunders Pdf

This book aims to demonstrate the intricacies of international tax planning. It is based around a case study of a fictitious Italian family with an abundance of personal and corporate tax issues. Each chapter analyses the laws applicable to the principle in question, then puts this firmly into context by reference to the case study.

Author : OECD
Publisher : OECD Publishing
Page : 78 pages
File Size : 54,6 Mb
Release : 2021-06-17
Category : Electronic
ISBN : 9789264572874

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Fighting Tax Crime – The Ten Global Principles, Second Edition by OECD Pdf

First published in 2017, Fighting Tax Crime - The Ten Global Principles is the first comprehensive guide to fighting tax crimes. It sets out ten essential principles covering the legal, institutional, administrative, and operational aspects necessary for developing an efficient and effective system for identifying, investigating and prosecuting tax crimes, while respecting the rights of accused taxpayers.

Author : Roy Rohatgi
Publisher : Unknown
Page : 467 pages
File Size : 40,6 Mb
Release : 2005
Category : Double taxation
ISBN : 0906524067

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Basic International Taxation: Principles of international taxation by Roy Rohatgi Pdf

Author : Ulrich Schreiber
Publisher : Springer Science & Business Media
Page : 179 pages
File Size : 51,7 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 : Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 49,9 Mb
Release : 2019-01-14
Category : Law
ISBN : 9789403501727

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International Tax Primer by Brian J. Arnold Pdf

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 : Peter Hongler
Publisher : Oxford University Press
Page : 289 pages
File Size : 46,5 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.