Download or read book Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America written by The Stationery Office and published by Stationery Office Books (TSO). This book was released on 2017-03-02 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dated February 2017. FATCA = Foreign Account Tax Compliance Act. The Agreement and Exchange of Notes entered into force on 11 August 2014. A TSO version of a title previously published by HM Government made available under the Open Government Licence v3.0(http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/)
Download or read book Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA written by Great Britain: Foreign and Commonwealth Office and published by . This book was released on 2017-02-27 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dated February 2017. The Agreement and Exchange of Notes entered into force on 11 August 2014. Print and web pdfs available at https://www.gov.uk/government/publications Web ISBN=9781474141307
Download or read book Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA written by and published by . This book was released on 2017 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA written by Great Britain. Foreign and Commonwealth Office and published by . This book was released on 2012-09-14 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Agreement is not yet in force. FATCA = Foreign Account Tax Compliance Act
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Download or read book Exchange of Notes Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America Updating and Amending the Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA Done at London written by Great Britain. Foreign and Commonwealth Office and published by . This book was released on 2013-06-13 with total page 13 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Exchange of notes is not in force. FATCA = Foreign Account Tax Compliance Act
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Download or read book International Taxation of Energy Production and Distribution written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2018-04-20 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.
Download or read book Global Tax Governance written by Peter Dietsch and published by ECPR Press. This book was released on 2016-01-01 with total page 405 pages. Available in PDF, EPUB and Kindle. Book excerpt: Commercial banks UBS and HSBC embroiled in scandals that in some cases exposed lawmakers themselves as tax evaders… multinationals Google and Apple using the Double Irish and other tax avoidance strategies… governments granting fiscal sweetheart deals behind closed doors (as in Luxembourg)... the stream of news items documenting the crisis of global tax governance is not about to dry up. Much work has been done in individual disciplines on the phenomenon of tax competition that lies at the heart of this crisis. Yet, the combination of issues of democratic legitimacy, social justice, economic efficiency, and national sovereignty that tax competition raises clearly requires an interdisciplinary analysis. This book offers a rare example of this kind of work, bringing together experts from political science, philosophy, law, and economics whose contributions combine empirical analysis with normative and institutional proposals. It makes an important contribution to reforming international taxation.
Download or read book International Taxation of Manufacturing and Distribution written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2016-02-18 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.
Download or read book Text of an Amendment to the Agreement Between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for Cooperation written by United States. President (2009-2017 : Obama) and published by . This book was released on 2014 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Automatic Exchange of Information Handbook written by John Hiddleston and published by Bloomsbury Publishing. This book was released on 2021-03-19 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Automatic Exchange of Information Handbook is a practical guide to the automatic exchange of information rules legislation within the UK. Covering the requirements of the OECD Common Reporting Standard (CRS), and the US Foreign Account Tax Compliance Act (FATCA) on financial institutions, this title helps to explain: - What the key jargon means - How to work out the status of an organisation under these rules (the definition of financial institutions may include professional firms, charities and trusts) - The potential penalties and other risks of non-compliance and how to minimise those risks - How to achieve compliance, including: - How to carry out the required due diligence - How to make a report The title summarises a brief history of AEOI, the impact of Brexit, who is affected and how, due diligence requirements, and more, as well as other issues including other forms of international information exchange such as anti-money laundering rules and bi-lateral double taxation treaties. Key points are clearly highlighted throughout for easy references and flowcharts are included to support some areas of commentary. This title is essential for tax advisers, accountants, tax lawyers, financial advisers and students studying for international tax qualifications. It will also be relevant for finance and management teams in organisations which fall under these rules in practice.
Download or read book Money Laundering Terrorist Financing and Tax Evasion written by Aretha M. Campbell and published by Springer Nature. This book was released on 2021-10-11 with total page 363 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains the consequences of global policy initiatives against money laundering, terrorist financing, and tax evasion on financial centres located in offshore jurisdictions in the Caribbean region. Adding to the existing literature by detailing international policy initiatives against money laundering and tax evasion from the early 1920s to date, this book examines the factors that have contributed to their gradual development over time, their role in contributing to money laundering, terrorist financing, and tax evasion, the international policy initiatives that came about to address these financial crimes, as well as the consequences of these policy initiatives on the legislative systems, institutions, offshore business sectors, and economies of these financial centres.
Download or read book Can Banks Still Keep a Secret written by Sandra Booysen and published by Cambridge University Press. This book was released on 2017-05-18 with total page 431 pages. Available in PDF, EPUB and Kindle. Book excerpt: An insight into bank secrecy in major jurisdictions, complemented by chapters on privacy, data protection, conflict of laws and exchange of information.
Download or read book Report 141 written by Australia. Parliament. Joint Standing Committee on Treaties and published by . This book was released on 2014 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
Download or read book Convention Between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland written by The United The United States and published by CreateSpace. This book was released on 2015-01-02 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland, Desiring to conclude a new Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains, Have agreed as follows:
