United Nations Handbook On Selected Issues For Taxation Of The Extractive Industries By Developing Countries

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United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries

Author : Department of Economic and Social Affairs
Publisher : United Nations
Page : 490 pages
File Size : 44,9 Mb
Release : 2019-02-24
Category : Political Science
ISBN : 9789210478472

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United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries by Department of Economic and Social Affairs Pdf

The United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries gives guidance to developing countries on key taxation issues during the life-cycle of an investment in the extractive industries, whether it be oil and gas or mining. The Handbook considers the options available to countries in this area, and their likely consequences. It addresses the balance needed to fight tax evasion and avoidance, while still having an attractive investment climate.

United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries

Author : United Nations Publications
Publisher : Unknown
Page : 490 pages
File Size : 42,8 Mb
Release : 2019-04-17
Category : Law
ISBN : 9211591236

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United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries by United Nations Publications Pdf

The Handbook highlights the issues developing countries should bear in mind when negotiating new contracts for the exploration and exploitation of natural and mineral resources within their territories. It covers the following topics: tax treaty issues; permanent establishment issues; indirect transfer of assets; transfer pricing issues; tax treatment of decommissioning; the government's fiscal take; tax aspects of negotiation and renegotiation of contracts; and value added taxation issues.

United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries

Author : United Nations Department of Economic and Social Affairs
Publisher : United Nations
Page : 592 pages
File Size : 51,6 Mb
Release : 2015-12-15
Category : Political Science
ISBN : 9789210572361

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United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries by United Nations Department of Economic and Social Affairs Pdf

Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources. This publication analyses a number of topics which are of particular interest and relevance to developing countries in raising revenues and protecting the tax base. It aims at providing practical assistance to these countries in assessing and addressing the relevant issues in an effective way. Primary audiences are officials of national tax authorities and ministries of finance in developing countries, other professionals dealing with tax matters, the general public, media and universities.

United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries

Author : United Nations Publications
Publisher : Unknown
Page : 792 pages
File Size : 49,7 Mb
Release : 2017-10-06
Category : Political Science
ISBN : 9211591112

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United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries by United Nations Publications Pdf

Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources.

United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries

Author : Alexander Trepelkov,Harry Tonino,Dominika Halka
Publisher : Unknown
Page : 0 pages
File Size : 55,8 Mb
Release : 2013
Category : Law
ISBN : 9211591058

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United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries by Alexander Trepelkov,Harry Tonino,Dominika Halka Pdf

"The UN Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries was developed as part of a project implemented jointly by FfDO and the International Tax Compact. Its ten chapters were drafted by renowned international tax experts on the basis of the inputs provided by officials from national tax authorities in 35 developing countries, representing all regions of the world. Through a novel demand-driven approach, it provides practical guidance to developing countries to effectively implement double tax treaties, especially those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries, having regard to the specific needs and interests of these countries."--Publisher website.

Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries

Author : United Nations Publications
Publisher : Unknown
Page : 158 pages
File Size : 53,5 Mb
Release : 2014
Category : Business & Economics
ISBN : UCBK:C113543837

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Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries by United Nations Publications Pdf

Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.

United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries

Author : United Nations Department of Economic and Social Affairs
Publisher : United Nations
Page : 196 pages
File Size : 44,6 Mb
Release : 2016-06-24
Category : Political Science
ISBN : 9789210576369

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United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries by United Nations Department of Economic and Social Affairs Pdf

The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries provides a guide to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.

Special Features of the UN Model Convention

Author : Anna Binder,Viktoria Wöhrer
Publisher : Linde Verlag GmbH
Page : 582 pages
File Size : 46,9 Mb
Release : 2019-10-01
Category : Law
ISBN : 9783709410400

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Special Features of the UN Model Convention by Anna Binder,Viktoria Wöhrer Pdf

Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.

Transfer Pricing Developments Around the World 2020

Author : Michael Lang,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 312 pages
File Size : 49,7 Mb
Release : 2020-09-28
Category : Law
ISBN : 9789403523934

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Transfer Pricing Developments Around the World 2020 by Michael Lang,Raffaele Petruzzi Pdf

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

Principles of International Taxation

Author : Lynne Oats
Publisher : Bloomsbury Publishing
Page : 773 pages
File Size : 48,5 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.

Tax Cooperation in an Unjust World

Author : Allison Christians,Laurens van Apeldoorn
Publisher : Oxford University Press
Page : 209 pages
File Size : 41,8 Mb
Release : 2021
Category : Tax planning
ISBN : 9780192848673

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Tax Cooperation in an Unjust World by Allison Christians,Laurens van Apeldoorn Pdf

The way that nation states design their tax systems impacts the sharing of resources and wealth within and across societies. To date, wealthy countries have made tax policy design and coordination choices which allow them to claim more than they are justifiably entitled to from the global economy. In Tax Cooperation in an Unjust World, Allison Christians and Laurens van Apeldoorn show how this presently accepted reality both facilitates and feeds off continued human suffering, and therefore violates conceptions of international distributive justice. They examine two principles that govern tax cooperation across states, and explain how the current international tax order impedes their realization. They then show how states could work toward fulfilling the principles and building a fairer international tax system via incremental yet effective adaptation of key international tax norms and rules.

African Gold

Author : Roman Grynberg,Fwasa K. Singogo
Publisher : Springer Nature
Page : 494 pages
File Size : 49,5 Mb
Release : 2021-04-22
Category : Business & Economics
ISBN : 9783030659950

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African Gold by Roman Grynberg,Fwasa K. Singogo Pdf

The book explores the evolving economics of gold as a global commodity as well as the production and trade of gold in and from the African continent. The growth of gold as an increasingly important and diverse source of African wealth is examined, alongside the impact that the rise of China in the 21st century has had on the demand for gold. The volatility of the gold price has increased as a result of the dramatic decline of gold demand for manufacturing purposes. Gold is Africa’s second largest export after oil and is a perfect metaphor for a continent rich in resources while so much of its population lives in such dire poverty. The artisanal and small scale gold mining (ASGM) sector, is surprisingly widely perceived as being beneficial to the development of Africa despite its exploitation and dreadful health and environmental consequences. African Gold: Production, Trade and Economic Development considers policy issues regarding the gold mining sector, the economics of beneficiation, the retreat of jewelry manufacturing across the continent as well as ‘Africa’s golden future’. It is a relevant book for both academics and policymakers interested in Africa, natural resource, and development economics.

The Institutional Topology of International Regime Complexes

Author : Benjamin Daßler
Publisher : Oxford University Press
Page : 305 pages
File Size : 44,7 Mb
Release : 2023-10-05
Category : Political Science
ISBN : 9780198881926

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The Institutional Topology of International Regime Complexes by Benjamin Daßler Pdf

The implicit topology of international institutional complexes varies greatly across policy areas. In some areas, the lion's share of everyday policy cooperation is shaped by a single institution with alternative and more regional institutions operating in its shadow. In other policy fields, institutional structures appear to be different, seeing a range of non-hierarchical, decentralized, alternative institutions. The Institutional Topology of International Regime Complexes: Mapping Inter-Institutional Structures in Global Governance provides a systematic conceptualization and explanation of the evolution of these varying institutional topologies underlying regime complexes across five issue areas of Global Governance: Intellectual Property Protection, Tax Avoidance, Financial Stability, Development Aid, and Energy Governance. By providing an empirically grounded, network-based conceptualization and mapping of institutional topologies, as well as a theoretical explanation for their variation across policy space and time, the book offers a comprehensive analysis of both the empirical manifestation of inter-institutional structures across various policy fields of Global Governance and the issue specific factors that shape the varying institutional trajectories spurring (de-) centralization. Daßler combines quantitative network analyses with qualitative case studies to trace institutional decentralization processes across five highly relevant issue areas of Global Governance. This volume shows how the nature of issue-specific cooperation problems translates into disparate structures among multilateral institutions occupying the same regime complex. In light of growing concerns about the future trajectories of Global Governance in times of heightened geopolitical tensions, Daßler offers a fresh perspective to comparatively capture the profoundly varying institutional landscapes across different issue areas and their associated challenges and benefits of multilateral cooperation. Transformations in Governance is a major academic book series from Oxford University Press. It is designed to accommodate the impressive growth of research in comparative politics, international relations, public policy, federalism, and environmental and urban studies concerned with the dispersion of authority from central states to supranational institutions, subnational governments, and public-private networks. It brings together work that advances our understanding of the organization, causes, and consequences of multilevel and complex governance. The series is selective, containing annually a small number of books of exceptionally high quality by leading and emerging scholars. The series is edited by Liesbet Hooghe and Gary Marks of the University of North Carolina, Chapel Hill, and Walter Mattli of the University of Oxford.

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option

Author : Richard Krever
Publisher : Kluwer Law International B.V.
Page : 307 pages
File Size : 49,6 Mb
Release : 2020-02-20
Category : Law
ISBN : 9789403506159

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The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option by Richard Krever Pdf

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246