Concept and Implementation of CFC Legislation


Book Description

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.




Concept and Implementation of CFC Legislation


Book Description

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.







Managing Urban Traffic Congestion


Book Description

Offers policy-oriented, research-based recommendations for effectively managing traffic and cutting excess congestion in large urban areas.




Towards Zero Ambitious Road Safety Targets and the Safe System Approach


Book Description

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.




Base Erosion, Profit Shifting and Developing Countries


Book Description

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.




International Nuclear Law


Book Description




Tax Treaty Override


Book Description

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.




Dictionary of Acronyms and Technical Abbreviations


Book Description

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.