Author : OECD
Publisher : OECD Publishing
Page : 92 pages
File Size : 42,11 MB
Release : 2011-08-03
Category :
ISBN : 9264119221
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
Author : OECD
Publisher : OECD Publishing
Page : 91 pages
File Size : 29,45 MB
Release : 2013-02-12
Category :
ISBN : 9264192743
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author : OECD
Publisher : OECD Publishing
Page : 92 pages
File Size : 31,91 MB
Release : 2011-08-31
Category :
ISBN : 9789264119215
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
Author : Donald A. Frederick
Publisher :
Page : 108 pages
File Size : 41,22 MB
Release : 1993
Category : Agricultural industries
ISBN :
Author : Christiana HJI Panayi
Publisher : Edward Elgar Publishing
Page : 663 pages
File Size : 48,56 MB
Release : 2020-01-31
Category : Law
ISBN : 1788110846
Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.
Author : Bruno da Silva
Publisher : Kluwer Law International B.V.
Page : 789 pages
File Size : 44,51 MB
Release : 2016-07-11
Category : Law
ISBN : 9041169091
Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.
Author : OECD
Publisher : OECD Publishing
Page : 110 pages
File Size : 49,82 MB
Release : 2013-07-29
Category :
ISBN : 9264200851
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.
Author : Juan Angel Becerra
Publisher : IBFD
Page : 299 pages
File Size : 15,77 MB
Release : 2007
Category : Canada
ISBN : 9087220197
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Author : Martin Klokar
Publisher : Linde Verlag GmbH
Page : 357 pages
File Size : 36,85 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 : Christiana HJI Panayi
Publisher : Bloomsbury Publishing
Page : 373 pages
File Size : 42,12 MB
Release : 2015-12-03
Category : Law
ISBN : 1849469547
This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world.
