United Nations Handbook On Selected Issues In Protecting The Tax Base Of Developing Countries
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United Nations Department of Economic and Social Affairs
Author : United Nations Department of Economic and Social Affairs Publisher : United Nations Page : 592 pages File Size : 41,7 Mb Release : 2015-12-15 Category : Political Science ISBN : 9789210572361
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 by United Nations Publications Pdf
Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources.
Author : Department of Economic and Social Affairs Publisher : United Nations Page : 490 pages File Size : 50,5 Mb Release : 2019-02-24 Category : Political Science ISBN : 9789210478472
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 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 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 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 Department of Economic and Social Affairs
Author : United Nations Department of Economic and Social Affairs Publisher : United Nations Page : 196 pages File Size : 53,6 Mb Release : 2016-06-24 Category : Political Science ISBN : 9789210576369
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.
Transfer Pricing and Developing Economies by Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra Pdf
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Edited by Parthasarathi Shome, this Handbook was written primarily for economists who are responsible for analyzing and evaluating economic policies of developing countries at an applied level, and who would benefit from a comprehensive discussion of the concepts, principles, and prevailing issues of taxation.
United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by United Nations Pdf
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
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.
Preventing Treaty Abuse by Daniel Blum,Markus Seiler Pdf
Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Author : International Monetary Fund Publisher : International Monetary Fund Page : 55 pages File Size : 41,6 Mb Release : 2016-07-20 Category : Business & Economics ISBN : 9781498345439
Enhancing the Effectiveness of External Support in Building Tax Capacity in Developing Countries by International Monetary Fund Pdf
This report responds to the February 2016 request from the G20 for the IMF, OECD, United Nations and World Bank Group to: “...recommend mechanisms to help ensure effective implementation of technical assistance programs, and recommend how countries can contribute funding for tax projects and direct technical assistance, and report back with recommendations at our July meeting.” The report has been prepared in the framework of the Platform for Collaboration on Tax (the “PCT”), under the responsibility of the Secretariats and Staff of the four mandated organizations. The report reflects a broad consensus among these staff, but should not be regarded as the officially endorsed views of those organizations or of their member countries.
Author : Department of Economic and Social Affairs Publisher : United Nations Page : 238 pages File Size : 48,6 Mb Release : 2019-06-28 Category : Law ISBN : 9789210042734
United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries 2019 by Department of Economic and Social Affairs Pdf
This manual provides insights 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.
This paper reviews conceptual linkages between taxation and unemployment, available empirical evidence and country policies that may have a bearing on these linkages in the OECD and in a sample of developing and transitional economies, Fund policy advice on these issues, and tax policy options in addressing the unemployment problem. It concludes that the emphasis in policy should be placed on minimizing tax distortions, rather than on formulating activist tax policies to reduce unemployment.
