Download or read book Denmark in International Tax Planning written by Nikolaj Bjørnholm and published by IBFD. This book was released on 2005 with total page 371 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides a comprehensive overview of the main issues involved in cross-border investment in and from Denmark. Begins by introducing the reader to Denmark and the basics of the Danish corporate law and tax system. A detailed analysis follows, examining the various aspects of Danish company law, corporate taxation and taxation of individuals, which are relevant when investing in or via Denmark. The principles of full and limited tax liability for both corporations and individuals are fully investigated. The unique "Danish Holding Regime", established by the Danish government to attract more foreign investment, is discussed in detail. Concludes with a section on tax planning and acquisition structures.
Download or read book Interpretation and Application of Tax Treaties written by Ned Shelton and published by Bloomsbury Professional. This book was released on 2011-12-31 with total page 700 pages. Available in PDF, EPUB and Kindle. Book excerpt: This new edition provides a fully updated, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Written by an expert in the field and taking the practical approach rather that the academic, this truly is an essential global tool for the tax adviser.
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 Denmark written by and published by . This book was released on 1991 with total page 127 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Tax Planning for U S MNCs with EU Holding Companies written by Pia Dorfmueller and published by . This book was released on 2003 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax planning for U.S. companies doing business in the EU. Analyses the design of tax conversion and deferral structures that are advantageous to U.S. multinationals to reach their goals: minimizing liability, maximizing credits, deducting expenses, and utilizing losses; using tools such as routing of income and classification of entities; and overcoming barriers like the CFC provisions of the U.S. tax law. Examines U.S. federal corporate law and analyses European company taxation, with specific tax planning techniques for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg, and Switzerland.
Download or read book Using Treaties and Holding Companies for Latin American Tax Planning written by Amanda D. Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005 with total page 170 pages. Available in PDF, EPUB and Kindle. Book excerpt: Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.
Download or read book Taxation in Denmark written by Denmark. Skattedepartementet and published by . This book was released on 1970 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Tax Planning written by Dennis Campbell and published by Springer. This book was released on 1995-05-19 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: The authors of International Tax Planning are tax specialists representing both high-tax and low-tax jurisdictions. They address tax issues that impact business enterprises as well as individuals, presenting a sampling of issues, each addressed by a commentator whose practice deals directly with such matters on a regular basis. Countries covered are: Austria France Germany Gibraltar Italy, Liechtenstein Spain Switzerland the Netherlands Netherlands Antilles U.S.A The reader will find a wealth of useful information, not only on the complexity of international taxation, but also its potential for the resolution of conflicts and the mitigation of unfair tax burdens through amortization and international cooperation.
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Download or read book Ireland in International Tax Planning written by Charles Haccius and published by IBFD. This book was released on 2004 with total page 1399 pages. Available in PDF, EPUB and Kindle. Book excerpt: Revised and updated edition providing the introduction to Irish tax legislation, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Follows practical discussion of Ireland's tax breaks, beginning with a discussion of the circumstances in which a company resident or carrying on business in Ireland qualifies for the 12.5% rate of corporation tax, and continuing with the issues of the tax efficient establishment and financing of a trading presence in Ireland, whether through a subsidiary or a permanent establishment or both. Possible tax planning opportunities are then discussed, both long standing tax breaks such as relief for artists and inventors, forestry, bloodstock and foreign domiciliaries, and opportunities such as those arising from the exercise of an employment in Ireland and the employment of crew members employed on ships or aircraft by an Irish resident company. The book also discusses transfer pricing and anti-avoidance provisions both in the Irish domestic tax legislation and in tax treaties.
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Download or read book The Principles of International Tax Planning written by Roy Saunders and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing and the Arm s Length Principle in International Tax Law written by Jens Wittendorff and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 914 pages. Available in PDF, EPUB and Kindle. Book excerpt: The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.
Download or read book The Principles Of International Tax Planning written by Roy Saunders and published by . This book was released on 2008-09-01 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is based around a case study of a fictitious Italian family with an abundance of personal and corporate tax issues. The work is presented in ten chapters, each covering a specific principle of international tax planning, such as Is the advice lawful? and Why are trusts useful in tax planning? Each chapter is split into two distinct sections. The first section analyses the law applicable to the principle in question, and the second puts this into context by reference to the case study. Accountants, bankers, lawyers, students, tax advisers and managers of trust companies will benefit from studying The Principles of International Tax Planning, either in depth or as a useful reference book. Because the book has been written by a firm specializing in International taxation, it considers the same questions and issues from the perspective of a number of different jurisdictions, such a France, Italy, South Africa, Switzerland, the UK and the US. Whether you are just interested in international tax, or whether international tax is your livelihood, your horizons will be broadened by reading this book, and you will have fun while doing so!
Download or read book Business Operations in Denmark written by Poul Erik Lytken and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... contains the basic information to enable a business to determine the best method of conducting its operations in Denmark from both a tax and a general legal point of view. It analyzes in detail the statutory and procedural framework of Danish income taxation as it applies to both individuals and corporations. This analysis also includes many other legal details vital to the organization of a Danish company. In addition to a detailed explanation of the income tax, the Portfolio discusses value added tax, and gift and inheritance tax"--Portfolio description (p. iii)
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.
