Download or read book The Taxation of Permanent Establishments written by Sven Hentschel and published by Springer Nature. This book was released on 2021-06-26 with total page 521 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.

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 Tax Systems and Tax Reforms in Europe written by Luigi Bernardi and published by Routledge. This book was released on 2004 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: This impressive book featuring contributions from leading scholars, will be of great interest not only to academics but also to those involved in the financial sectors across the world.

Download or read book Treaty Shopping written by Helmut Becker (Rechtsanwalt.) and published by Springer. This book was released on 1988-07-13 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: The concept treaty shopping is explained. The papers prepared as a response to the questionnaire from different countries for an International Workshop of Deloitte Haskins & Sells in Düsseldorf, Germany is published. The countries covered are: Australia, Austria, Belgium, Canada, Cyprus, Denmark, Finland, France, German Federal Republic, Italy, Luxembourg, the Netherlands, Norway, Singapore, Spain, Sweden, Switzerland, the United Kingdom and the USA.

Download or read book CGE Models and Capital Income Tax Reforms written by Doina Maria Radulescu and published by Springer Science & Business Media. This book was released on 2007-08-28 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book suggests a novel way how the effects of tax reforms especially in the field of capital income taxation can be measured by means of dynamic computable general equilibrium (CGE) models. Using a model calibrated to the German economy, the author evaluates and quantifies the effects of introducing a Dual Income Tax (DIT) in Germany. This tax reform is a currently hotly debated topic in Germany and has been suggested both by the German Council of Economic Advisors (GCEA) and by Prof. Hans-Werner Sinn. Thus, the book is of great interest not only for the academic but also for the business world and politics.

Download or read book Taxing Wages 2019 written by OECD and published by OECD Publishing. This book was released on 2019-04-11 with total page 643 pages. Available in PDF, EPUB and Kindle. Book excerpt: This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by in-work families. It ...

Download or read book Doing Business 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-21 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.

Download or read book Alcohol Taxation and Regulation in the European Union written by Sijbren Cnossen and published by . This book was released on 2006 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation Actions 8 10 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

Download or read book Assessing the Theory and Practice of Land Value Taxation written by Richard F. Dye and published by Lincoln Inst of Land Policy. This book was released on 2010 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: The land value tax is the focus of this Policy Focus Report, Assessing the Theory and Practice of Land Value Taxation. A concept dating back to Henry George, the land value tax is a variant of the property tax that imposes a higher tax rate on land than on improvements, or taxes only the land value. Many other types of changes in property tax policy, such as assessment freezes or limitations, have undesirable side effects, including unequal treatment of similarly situated taxpayers and distortion of economic incentives. The land value tax can enhance both the fairness and the efficiency of property tax collection, with few undesirable effects; land is effectively in fixed supply, so an increase in the tax rate on land value will raise revenue without distorting the incentives for owners to invest in and use their land. A land value tax has also been seen as a way to combat urban sprawl by encouraging density and infill development. Authors Richard F. Dye and Richard W. England examine the experience of those who have implemented the land value tax -- more than 30 countries around the world, and in the United States, several municipalities dating back to 1913, when the Pennsylvania legislature permitted Pittsburgh and Scranton to tax land values at a higher rate than building values. A 1951 statute gave smaller Pennsylvania cities the same option to enact a two-rate property tax, a variation of the land value tax. About 15 communities currently use this type of tax program, while others tried and rescinded it. Hawaii also has experience with two-rate taxation, and Virginia and Connecticut have authorized municipalities to choose a two-rate property tax. The land value tax has been subjected to studies comparing jurisdictions with and without it, and to legal challenges. A land value tax also raises administrative issues, particularly in the area of property tax assessments. Land value taxation is an attractive alternative to the traditional property tax, especially to much more problematic types of property tax measures such as assessment limitations, the authors conclude. A land value tax is best implemented if local officials use best assessing practices to keep land and improvement values up to date; phase in dual tax rates over several years; and include a tax credit feature in those communities where land-rich but income-poor citizens might suffer from land value taxation.

Download or read book Comparison of the Tax Systems of the United States the United Kingdom Germany and Japan written by and published by . This book was released on 1992 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Complex Systems Innovation and Sustainability in the Digital Age written by Aleksei V. Bogoviz and published by Springer Nature. This book was released on 2020-05-13 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text provides one of the first book-length studies on the innovative and sustainable development of complex systems in the era of digital transformations, combining quantitative data from several countries with detailed qualitative accounts at the national level. In particular, the book covers the basic concepts, methods, and cutting-edge research on innovation and sustainability in complex systems. Given its scope, the book will be of great interest and value to researchers and practitioners working across the social sciences and in a diverse range of areas in complexity science. Pursuing a multidisciplinary approach, the book is also an ideal resource for advanced undergraduate and graduate level courses in complexity science, sustainability research, economics, and development studies.

Download or read book The Politics of Income Taxation written by Steffen Ganghof and published by ECPR Press. This book was released on 2024-10-31 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: Marginal income tax rates in advanced industrial countries have fallen dramatically since the mid-1980s, but levels and progressivity of income taxation continue to differ strongly across countries. This study offers a new perspective on both observations. It blends theoretical inquiry with focused quantitative analysis and in-depth investigation of seven countries: Germany, Australia and New Zealand as well as Denmark, Finland, Norway and Sweden. The Politics of Income Taxation highlights the equity-efficiency tradeoffs that structure the politics of income taxation, and analyses how income taxes are embedded in broader tax systems. It explains the limited but enduring importance of political parties and democratic institutions. Finally, the study paints a nuanced picture of the role of globalisation and thus sheds light on the pros and cons of tax coordination at European and international levels.

Download or read book Description and Analysis of Present law Tax Rules Relating to Income Earned by U S Businesses from Foreign Operations written by and published by . This book was released on 1995 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Comparative Tax Systems written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 1993 with total page 200 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Germany Country Study Guide Volume 1 Strategic Information and Developments written by IBP, Inc and published by Lulu.com. This book was released on 2012-03-03 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Germany Country Study Guide - Strategic Information and Developments Volume 1 Strategic Information and Developments

Download or read book Why People Pay Taxes written by Joel Slemrod and published by . This book was released on 1992 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: Experts discuss strategies for curtailing tax evasion