Download or read book Belgium in International Tax Planning written by Patrick A. A. Vanhaute and published by IBFD. This book was released on 2008 with total page 490 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book focuses on commercial and company law and corporate income tax. It provides a systematic and comprehensive overview of the current tax planning opportunities that exist in Belgium. After some essential legal knowledge of Belgium, the chapters consider the Belgian tax regime, special features of the Belgian tax system, specific anti-avoidance provisions and international tax planning, tax incentives, special tax regimes, and tax planning opportunities (including the tax treaties with Hong Kong, the USA and the UAE).
Download or read book International Tax Planning and Prevention of Abuse written by Luc De Broe and published by IBFD. This book was released on 2008 with total page 1146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Download or read book The Principles of International Tax written by Adrian Ogley and published by International Information Services Incorporated. This book was released on 1993 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.
Download or read book Tax Planning with Holding Companies Repatriation of US Profits from Europe written by Rolf Eicke and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 526 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Download or read book The Netherlands in International Tax Planning written by Johann Müller (podatki) and published by IBFD. This book was released on 2007 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
Download or read book Tax Planning for International Mergers Acquisitions Joint Ventures and Restructurings 5th Edition written by Peter H. Blessing and published by Kluwer Law International B.V.. This book was released on 2020-03-10 with total page 7048 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon
Download or read book Tax Treaties and Domestic Law written by Guglielmo Maisto and published by IBFD. This book was released on 2006 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Download or read book Tax Planning for International Mergers Acquisitions Joint Ventures and Restructurings written by Ansgar A. Simon and published by Kluwer Law International B.V.. This book was released on 2023-08-31 with total page 2424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.
Download or read book International Tax Handbook written by and published by Bloomsbury Publishing. This book was released on 2015-01-01 with total page 829 pages. Available in PDF, EPUB and Kindle. Book excerpt: This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277
Download or read book Practical International Tax Planning written by Marshall J. Langer and published by . This book was released on 1999 with total page 1626 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Tax as International Law written by Reuven S. Avi-Yonah and published by Cambridge University Press. This book was released on 2007-09-10 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
Download or read book Hungary in International Tax Planning written by Dániel Deák and published by IBFD. This book was released on 2003 with total page 486 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth survey of the Hungarian tax system from the perspective of domestic and international tax planning. Detailed analysis of the principles of the taxation of resident corporations and foreign enterprises (with and without permanent establishments). The taxation of the income of individuals is reviewed in broad terms. Compulsory social insurance contributions and related charges are discussed. Registration duties, local rates, tax administration and anti-avoidance measures are discussed in brief.
Download or read book International Tax Planning written by William C. Gifford and published by . This book was released on 1979 with total page 760 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Global Tax Environment in 2016 and Implications for International Tax Reform written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 2017 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Taxation and Value Creation written by Werner C. Haslehner and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
