CFC Legislation in the European Union and the Alternative CSC Concept
Author : Robert Gebhard Bader
Publisher :
Page : 697 pages
File Size : 47,57 MB
Release : 2012
Category :
ISBN :
Author : Robert Gebhard Bader
Publisher :
Page : 697 pages
File Size : 47,57 MB
Release : 2012
Category :
ISBN :
Author : Nathalie Bravo
Publisher : Linde Verlag GmbH
Page : 423 pages
File Size : 34,69 MB
Release : 2021-09-21
Category : Law
ISBN : 3709411599
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author : Nathalie Bravo
Publisher : Linde Verlag GmbH
Page : 536 pages
File Size : 11,65 MB
Release : 2021-09-21
Category : Law
ISBN : 3709411580
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author : United States. Joint Chiefs of Staff
Publisher :
Page : 392 pages
File Size : 13,89 MB
Release : 1979
Category : Military art and science
ISBN :
Author : European Conference of Ministers of Transport
Publisher : OECD Publishing
Page : 294 pages
File Size : 39,97 MB
Release : 2007-05-31
Category :
ISBN : 9282101509
Offers policy-oriented, research-based recommendations for effectively managing traffic and cutting excess congestion in large urban areas.
Author : International Transport Forum
Publisher : OECD Publishing
Page : 245 pages
File Size : 23,96 MB
Release : 2008-09-23
Category :
ISBN : 9282101967
This report takes stock of recent developments and initiatives to meet increasingly ambitious road safety targets, and constitutes a major international review of progress in developing Safe System approaches, now adopted in a small number of countries.
Author : Ernesto Crivelli
Publisher : International Monetary Fund
Page : 30 pages
File Size : 21,75 MB
Release : 2015-05-29
Category : Business & Economics
ISBN : 1513567624
International corporate tax issues are prominent in public debate, notably with the G20-OECD project addressing Base Erosion and Profit Shifting (‘BEPS’). But while there is considerable empirical evidence for advanced countries on the cross-country fiscal externalities at the heart of these issues, there is almost none for developing countries. This paper uses panel data for 173 countries over 33 years to explore their magnitude and nature, focusing particularly on developing countries and applying a new method to distinguish between spillover effects through real decisions and through avoidance —and quantify the revenue impact of the latter. The results suggest that spillover effects on the tax base are if anything a greater concern for developing countries than for advanced—and a significant one.
Author :
Publisher :
Page : 423 pages
File Size : 45,18 MB
Release : 2010
Category : Nuclear energy
ISBN : 9789264991439
Author : Carla De Pietro
Publisher : Kluwer Law International
Page : 0 pages
File Size : 38,70 MB
Release : 2014
Category : Conflict of laws
ISBN : 9789041154064
The term è^-treaty overrideè^-- has acquired a specific connotation for tax treaty purposes, which requires an in-depth analysis. There is a tendency for domestic legislation to be passed (or court cases decided) which may override provisions of tax treaties. Despite the many conflicts and uncertainties about what tax treaty override exactly is and the exact point in time when tax treaty override occurs, its implications have not until now been analysed in a systematic manner.
Author : Jakob Vlietstra
Publisher : Springer Science & Business Media
Page : 703 pages
File Size : 33,13 MB
Release : 2012-12-06
Category : Computers
ISBN : 1447102630
This Dictionary covers information and communication technology (ICT), including hardware and software; information networks, including the Internet and the World Wide Web; automatic control; and ICT-related computer-aided fields. The Dictionary also lists abbreviated names of relevant organizations, conferences, symposia and workshops. This reference is important for all practitioners and users in the areas mentioned above, and those who consult or write technical material. This Second Edition contains 10,000 new entries, for a total of 33,000.