Author : OECD
Publisher : OECD Publishing
Page : 82 pages
File Size : 17,25 MB
Release : 1998-05-19
Category :
ISBN : 9264162941
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author : Valentin Bendlinger
Publisher : Linde Verlag GmbH
Page : 510 pages
File Size : 27,51 MB
Release : 2024-10-18
Category : Law
ISBN : 3709413478
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two
Author : PEDRO SCHOUERI.
Publisher :
Page : pages
File Size : 20,41 MB
Release : 2019
Category :
ISBN : 9789087225827
Author : Pedro Guilherme Lindenberg Schoueri
Publisher :
Page : 324 pages
File Size : 30,19 MB
Release : 2019
Category :
ISBN : 9789087225810
This book sheds light on the complexity of the environment in which the BEPS Project operates. It contrasts the commands of the modified nexus approach (BEPS Action 5) with those of EU law, WTO law and international investment agreements. Though it is clear that, as soft law, the Actions of the BEPS Project should remain within the limits established by hard law, the book identifies several instances in which this line has been crossed by the modified nexus approach.0 0This conflict between hard and soft law frameworks is treated as analogous to the notion of fragmentation of international law and, against this backdrop, the book proposes that the notion of institutional dialogue could help build a pathway for a more productive relationship between these frameworks.
Author : Martin Klokar
Publisher : Linde Verlag GmbH
Page : 357 pages
File Size : 14,46 MB
Release : 2023-10-03
Category : Law
ISBN : 3709412986
An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021-23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.
Author : Florian Navisotschnigg
Publisher : Kluwer Law International B.V.
Page : 233 pages
File Size : 27,59 MB
Release : 2022-08-09
Category : Law
ISBN : 940354905X
The notion of ‘substance’ is proving to be central to the OECD’s base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership). In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions: What substance is necessary to be entitled to intangible-related returns? What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions? What substance is necessary to collect royalties free from withholding taxes? Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles. It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles.
Author : Thomas Pogge
Publisher : Oxford University Press
Page : 383 pages
File Size : 11,7 MB
Release : 2016-02-04
Category : Business & Economics
ISBN : 019103861X
This book addresses sixteen different reform proposals that are urgently needed to correct the fault lines in the international tax system as it exists today, and which deprive both developing and developed countries of critical tax resources. It offers clear and concrete ideas on how the reforms can be achieved and why they are important for a more just and equitable global system to prevail. The key to reducing the tax gap and consequent human rights deficit in poor countries is global financial transparency. Such transparency is essential to curbing illicit financial flows that drain less developed countries of capital and tax revenues, and are an impediment to sustainable development. A major break-through for financial transparency is now within reach. The policy reforms outlined in this book not only advance tax justice but also protect human rights by curtailing illegal activity and making available more resources for development. While the reforms are realistic they require both political and an informed and engaged civil society that can put pressure on governments and policy makers to act.
Author : Florian Haase
Publisher : Oxford University Press
Page : 1185 pages
File Size : 24,66 MB
Release : 2023-09-22
Category : Law
ISBN : 0192652346
International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
Author : Edoardo Favari
Publisher : Springer Nature
Page : 341 pages
File Size : 23,32 MB
Release : 2023-05-31
Category : Science
ISBN : 3031308794
This book showcases the discussion about megaprojects carried out at the MeRIT (Megaproject Research Interdisciplinary Team) workshop 2022: the crisis, discontinuity, rising prices, and supply chains disruption force radical reflection for those involved in megaprojects. It raises a modern-day challenge, the creation of value for stakeholders. Indeed, the aim of the volume is to encourage readers to think more broadly, articulately and less stringently than the mainstream claims. There is a need to design, implement, and manage megaprojects by abandoning the old paradigm that leveraged solely on time and cost. We need to move beyond that by going to explore the value generated, the positive impact on people, communities and territories. Economic, social and environmental sustainability takes on a new and broader articulation: issues of the circular economy applied to megaprojects are addressed and ample space is ensured for the inclusion of social needs in current practices.
Author : Terence C. Halliday
Publisher : Cambridge University Press
Page : 559 pages
File Size : 40,84 MB
Release : 2015-01-19
Category : Business & Economics
ISBN : 1107069920
Transnational Legal Orders offers an empirically grounded approach to the emergence of legal orders beyond nation-states that reframes the study of law and society.
