Download or read book The New Permanent Establishment written by Tiago Gonçalves Marques and published by Leya. This book was released on 2023-04-21 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.

Download or read book Governance and Risk Management in Taxation written by Arnaldo Marques de Oliveira Neto and published by Springer. This book was released on 2016-10-13 with total page 183 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides insights into identifying and dealing with possible corporate tax risks. It also elaborates on how enterprises can avoid possible issuance of notices of violation, fines and default interest, and ensure reduced tax responsibility of enterprises and their administrators when dealing with tax issues, thereby bringing about increased efficiency and productivity.Conducted in collaboration with the Brazilian Enterprises Group of Advertising and Publicity Services, it also includes managerial information resources and procedures for tax risks that enterprises may encounter. Additionally, it presents findings that allow the academic community and enterprises (not only advertising and publicity services) alike to benefit from the results derived from the Model of Corporate Risk Management (GRCorp) and the Specific Model of Tax Risk Management (GRTrib) frameworks developed by the author. The book serves as a valuable resource for academic researchers and practitioners in businesses.

Download or read book Sustainable Finances and the Law written by Rute Saraiva and published by Springer Nature. This book was released on with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book State Tax Competition Guerra Fiscal written by Sergio Mitsuo Vilela and published by Editora Dialética. This book was released on 2023-08-29 with total page 83 pages. Available in PDF, EPUB and Kindle. Book excerpt: Brazil has a very peculiar tax collection power distribution and revenue sharing system, that splits three way the consumption tax, giving taxation powers over goods circulation to the States, over services to the Municipalities and over production to the Union. The Brazilian State circulation of goods tax, whose regulations require unanimity to incentives and benefits concessions, even though the 27 Brazilian States development state are disparate, generates a "fiscal war" / State competition that costs 30 billion Brazilian Reais (6 billion Swiss Francs) yearly and the attempts at settling State Competition are clearly failing, while Switzerland, which has a similar political organization, seems to have a reasonable and functional system. This dissertation, requirement for the obtaining the title of Doctor in International Tax law, takes a case study approach to compare these two systems, specifically taxable events, financial transfer mechanisms and their rules to avoid State / Canton tax competition to assess if the Swiss system for tax collection power distribution and revenue sharing is a feasible solution to reduce the adverse effects of State tax competition in Brazil.

Download or read book Manual de Direito do Trabalho written by Fßbio Villela and published by Elsevier. This book was released on 2012 with total page 797 pages. Available in PDF, EPUB and Kindle. Book excerpt: Manual De Direito Do Trabalho.

Download or read book Trusts in Latin America written by Nicolás Malumián and published by Oxford University Press. This book was released on 2009 with total page 426 pages. Available in PDF, EPUB and Kindle. Book excerpt: The growing interest in investment in Latin America - particularly in commodities production and real estate development - has increased the use of trusts as investment vehicles throughout Latin America. Written for the English-speaking practitioner, the book covers Argentina, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Honduras, México, Panamá, Paraguay, Perú, Uruguay and Venezuela and provides a practical, clear, and thorough explanation of trusts as legal vehicles for investment in Latin American countries. Trusts in Latin America provides a comprehensive, comparative review of statutes, case law, and examples of trusts in Latin America, and also highlights differences between these countries and common-law systems.

Download or read book Portuguese Economic Development and External Funding in the Modern Era written by Nuno Cunha Rodrigues and published by Liverpool University Press. This book was released on 2021-10-27 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: After World War II, with the triumph of multilateralism, several international organizations were created, including two which would be of special importance for the external funding of the Portuguese economy in the second half of the twentieth century and in the early twenty-first. The European Union and the International Monetary Fund have been responsible for providing large amounts of funding, both in periods of economic development and during times of financial crisis. This contributory volume provides a thorough analysis on specific case studies: the Marshall Plan (1949-1952); the three IMF interventions (in the seventies, eighties and the 2011 bailout); the implementation of the first EU funds Portugal received prior to accession; and the debate on the new framework for European funds for the period 2021-2027. These case study analyses provide an overview of the legal, economic and financial implications that such external funding has on the country at different times and in different economic contexts. Of particular import at all times is the public finance legal framework, and this is especially the case for the new European funding structures, which has attracted some criticism. And for any future IMF financial assistance and its political implementation implications. Portuguese Economic Development and External Funding in the Modern Era provides important insights into economic development, crisis management, financial assistance and European investment funds. While the work is Portuguese-centred, the topics investigated and the means of analysis adopted are applicable to other countries. This is the first book to address economic development and external funding, and it will inevitably be used as a template for future research.

Download or read book A B blia e a Fonte Hist rica do Direito written by Erivaldo de Jesus and published by Assembleia de Deus Oficial. This book was released on with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Double Taxation Conventions and Social Security Conventions written by Michael Lang and published by . This book was released on 2006 with total page 780 pages. Available in PDF, EPUB and Kindle. Book excerpt: As social security systems can be based on contributions as well as on taxes, it is of international interest to investigate the relation between double tax conventions and social security conventions. This book points out similarities as well as differences between these two types of conventions. 18 National Reports from nearly all EU countries as well as Israel, New Zealand, Russia and the USA on this topic are compiled and published in this volume. The National Reports partly focus on the comparison of certain types of provisions contained in such conventions, for example anti-discrimination clauses or the provisions concerning migrant workers. Moreover, multilateral conventions as well as EC law and the jurisdiction of the ECJ are the basis of this book. Additionaly, experts in this field have volunteered contributions dealing with specific problems of tax treaties and social security conventions.

Download or read book JUSTI A E DEMOCRACIA as novas perspectivas da hermen utica constitucional written by Renata Furtado de Barros and published by Lulu.com. This book was released on 2012-12-10 with total page 501 pages. Available in PDF, EPUB and Kindle. Book excerpt: A ABPJD (Academia Brasileira de Produção Jurídica Discente) apresenta seu terceiro livro produzido com a colaboração de diversos profissionais da área jurídica, intitulado: "JUSTIÇA E DEMOCRACIA: as novas perspectivas da hermenêutica constitucional". Essa obra é fruto de inúmeras pesquisas dos alunos do curso de Pós-Graduação em Direito da PUC Minas, tendo contado com a colaboração de diversos docentes e discentes de outras instituições espalhadas por todo o Brasil. Com o objetivo de facilitar a leitura, a obra foi dividida em dois volumes, sendo este o primeiro volume. O que se busca a todo momento é crer em um ordenamento jurídico mais justo e democrático, para tanto, entendemos que a hermenêutica é um caminho seguro para reflexão da aplicação das normas no Estado Democrático de Direito brasileiro. Esperamos que esse livro seja uma reflexão da hermenêutica constitucional e de seu papel na manutenção de ideais mais sólidos de Justiça e Democracia. As Organizadoras.

Download or read book Compendio historica do estado da Universidade de Coimbra no tempo da invas o dos denominados Jesuitas e dos estragos feitos nos sciencias e nos professores e directores que a regiam pelas maquina es e publica es dos novos Estatutos por elles fabricados written by Universidade de Coimbra (COIMBRA) and published by . This book was released on 1771 with total page 508 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

Download or read book Bibliographic Guide to Latin American Studies 1996 written by G K HALL and published by Macmillan Reference USA. This book was released on 1997-07 with total page 1086 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Theory of Legal Principles written by Humberto Avila and published by Springer Science & Business Media. This book was released on 2007-09-26 with total page 166 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the distinction between principles and rules so that they can be better understood and applied. It structures the distinction between principles and rules on different foundations than those jurisprudence ordinarily employs. It also proposes a new model to explain the normative species, which includes structured weighing on the application process while encompassing substantive criteria of justice in its argument.

Download or read book Constitutional Knowledge and Its Impact on Citizenship Exercise in a Networked Society written by Melro, Ana and published by IGI Global. This book was released on 2019-03-15 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt: National constitutions allow citizens to exercise full citizenship rights, leading to a growing importance in understanding these laws. This knowledge, more widespread thanks to the ever-growing use of digital networks, allows for more enlightened national citizens in every corner of the world. Constitutional Knowledge and Its Impact on Citizenship Exercise in a Networked Society is a pivotal reference source that analyzes how constitutional awareness occurs in various countries and how citizenship participation is encouraged through the use of digital tools. While highlighting topics such as mobile security, transparency accountability, and constitutional awareness, this publication is ideally designed for professionals, students, academicians, and policymakers seeking current research on citizens' lack of awareness of their rights.

Download or read book Certainty in Law written by Humberto Ávila and published by Springer. This book was released on 2016-07-20 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Instead of the usual apologetic treatment found in legal doctrine, linked to the determinacy, immutability or predictability of norms, this book treats legal certainty innovatively, holistically and in depth. Using a method at once analytical and functional, Professor Ávila examines the structural elements of legal certainty, from its definition and foundations to its various dimensions, normative forces and efficacies, citing a wealth of examples from case law to support each of the theses defended. No subject is more important and topical than legal certainty. Problems relating to lack of understanding, instability and unpredictability of law intensify day by day everywhere, in civil law and common law countries alike. Normative sources are increasingly diverse in origin (national, international, community) and multiple in nature (legal, contractual, jurisprudential). They change constantly, and present increasingly frequent problems of ambiguity and vagueness that significantly hinder their comprehension. This state of affairs, which to a greater or lesser extent is true of any legal order, justifies a return to the subject of legal certainty. In this book, essential questions are answered such as: Legal certainty in what sense? Certainty of what, for whom, in whose vision and by whom? When, to what extent, and to what end? “(...) it is probably the most comprehensive and systematic study ever produced on this subject using the analytical method.” (Riccardo Guastini, Professor of Jurisprudence, University of Genoa, Italy)

Download or read book Individuals Income under Double Taxation Conventions A Brazilian Approach written by Daniel Vitor Bellan and published by Kluwer Law International B.V.. This book was released on 2010-09-03 with total page 466 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax conventions (or tax treaties) provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. Brazil has over two dozen such conventions in force. This number might seem small but the country will inevitably enter into more such treaties given its economic growth, foreign investments and economic globalization in general. Two highly practical aspects form the basis of the book’s analysis: interpretation and qualification under international tax law; and Brazil’s income tax on individuals. The author employs those starting points to tackle such thorny questions as: Is there coherence in the legal regime that is applicable to individuals’ income in double taxation treaties? Is this “system” for individuals consistent? Is it in accordance with Brazilian constitutional principles? Professionals dealing with Brazil’s tax regime will quickly find this work instructive, insightful and thought-provoking.