Download or read book Cross Border Investments with Germany Tax Legal and written by Detlev J. Piltz and published by . This book was released on 2014-12-11 with total page 686 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Cross Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.

Download or read book Taxation of Enterprises in Germany written by Jochen Bahns and published by C.H.Beck. This book was released on 2024-07-30 with total page 1273 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysing the implications of German tax law for domestic and foreign enterprises, particularly in M&A and reorganisations, requires an understanding of the prerequisites and legal consequences of the German tax law. In an international context, a more than challenging exercise, especially due to the complex German terminology. Written in English, this book provides clear and essential information on core aspects and key questions concerning German tax law, including Income taxation of individuals and corporations Taxation of partnerships Tax matters in inbound and outbound activities Taxation in M&A transactions and corporate reorganisations This detailed and practice-orientated guide provides international and domestic legal and tax advisors, as well as investors, with comprehensive information on German tax law in a commercial setting. Dr. Jochen Bahns is a qualified attorney and tax advisor specialising in international tax law and corporate tax law.

Download or read book Taxation of Income from Domestic and Cross border Collective Investment written by Andreas Oestreicher and published by Springer Science & Business Media. This book was released on 2013-07-30 with total page 170 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.

Download or read book International Taxation of Cross border Leasing Income written by Amar Mehta and published by IBFD. This book was released on 2005 with total page 307 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.

Download or read book German Tax Guide written by Robert Amann and published by Springer. This book was released on 2001-08-06 with total page 1440 pages. Available in PDF, EPUB and Kindle. Book excerpt: Here For The first time in English is a full-scale, authoritative analysis of German tax law for use in international business transactions and investment activities. An expert team of fifteen experienced tax lawyers from Germany And The United States provides detailed practical commentary on the ground rules of internationally relevant German tax law, including the following crucial areas: sources of German tax law; taxes applicable to international business; details of the major tax reform now under way; double taxation treaties; taxation of nonresident individuals; corporate tax; tax implications of reorganizations and acquisitions; and accounting and reporting procedures. Throughout the presentation, terminology appears in both English and German. An appendix contains the major German tax laws in parallel English and German text. This is the ideal practical resource for companies and individuals resident abroad who must deal with cross-border tax issues as they invest or do business under German law. Including as it does references, As they arise in context, To the major German tax reform of 1999-2002, German Tax Guide is unlikely to be superseded for many years.

Download or read book International Company Taxation written by Ulrich Schreiber and published by Springer Science & Business Media. This book was released on 2013-01-30 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

Download or read book Taxing German Dutch Cross Border Activities written by Bert Alink and published by Institut für Finanz- und Steuerrecht, Universität Osnabrück. This book was released on 2015-02-04 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.

Download or read book Legal Interpretation of Tax Law written by Robert F. van Brederode and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Legal Interpretation of Tax Law' is a comprehensive multi-jurisdiction survey of the interpretation of the corporate income tax and VAT and GST or other general sales tax laws. As a result of the globalization of trade and business, tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions. Effective consulting, whether internal or external, requires not only knowledge of tax law per se but also of how tax law is explained and interpreted by the courts of foreign jurisdictions. This book is the first to deal comparatively with tax law interpretation in economies engaged in cross-border investment at a global level.00The introduction outlines the theoretical approaches to legal interpretation in general and gives an overview of issues and topics relevant to taxation ? designed to help readers understand the jurisdictional chapters that follow. Each author pays detailed attention to such documentary elements as explanatory memoranda, administrative rulings, judicial precedents, judgments of foreign courts, legislative debates, and OECD guidelines.

Download or read book Germany Taxation Laws and Regulations Handbook Volume 1 Strategic Information and Corporate Taxation written by IBP USA and published by Lulu.com. This book was released on with total page 296 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 241 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 Legal Aspects of Doing Business in Europe 2009 II written by Christian, Editor Campbell and published by Lulu.com. This book was released on 2009 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: Vol II 2009 France-Moldova. "Legal Aspects of Doing Business in Europe", a three-volume set, with more than 1,400 pages, provides a survey of the requirements for doing business and investing in Europe. The reports are prepared by local business practitioners and offer practical insights into issues relating to selection of form for doing business, incentives, taxation, labor and employment, liabilities, and dispute resolution. Order volumes I and III to complete the set. The publication is replaced by an updated volume annually. Purchase includes 24/7 online access. A 10% discount applies to a subscription for next year's update. A 25% discount applies to a subscription for three years of updates. Discounts are applied after purchase by rebate from publisher.

Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).

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 Avoidance and European Law written by Mihaela Tofan and published by Taylor & Francis. This book was released on 2022-06-07 with total page 85 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax law is one of the legal fields with the most subtle influence on European integration and EU law. The European economic cooperation project emerged with the customs union, essentially a tax law concept, and evolved alongside other topics of tax harmonization. Still, the existence of the EU tax law is disputed. The research on the topic is significant, as the integration of national economies and markets has increased substantially, both within the EU and globally. This has put a strain on domestic tax rules, which are subject to the demands of the international taxation requirements. This book explores the relationship between tax avoidance regulation and sovereignty within the European Union, analyzing the impact of the effective regulatory methods for limiting and eliminating aggressive tax planning by multinational companies. Focusing on analyzing good practice in fiscal regulation efficiency and the results generated by the tax jurisprudence both at national and European level, its main objective is to present the argument for inter-dependency between taxation and the current changes in the concept of sovereignty. It highlights where fiscal regulation has led to uniform, yet flexible, solutions for the actual fight against companies’ abusive fiscal conduct, when taking advantage of tax competition. This text will be of value to academics, researchers, and advanced students in tax law and tax avoidance regulation and their intersection with sovereignty in the context of the European Union.

Download or read book What Is Real and What Is Not in the Global FDI Network written by Jannick Damgaard and published by International Monetary Fund. This book was released on 2019-12-11 with total page 54 pages. Available in PDF, EPUB and Kindle. Book excerpt: Macro statistics on foreign direct investment (FDI) are blurred by offshore centers with enormous inward and outward investment positions. This paper uses several new data sources, both macro and micro, to estimate the global FDI network while disentangling real investment and phantom investment and allocating real investment to ultimate investor economies. We find that phantom investment into corporate shells with no substance and no real links to the local economy may account for almost 40 percent of global FDI. Ignoring phantom investment and allocating real investment to ultimate investors increases the explanatory power of standard gravity variables by around 25 percent.