Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Download or read book Spanish Yearbook of International Law written by and published by . This book was released on 2001 with total page 570 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Global Investment Competitiveness Report 2017 2018 written by World Bank Group and published by World Bank Publications. This book was released on 2017-10-25 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Global Investment Competitiveness report presents new insights and evidence on drivers of foreign direct investment (FDI) in developing countries, and FDI’s role in development. The report’s survey of 750 executives of multinational corporations finds that a business-friendly legal and regulatory environment is a key driver of investment decisions in developing countries, along with political stability, security, and macroeconomic conditions. The report’s topic-specific chapters explore the potential of FDI to create new growth opportunities for local firms, assess the power of tax holidays and other fiscal incentives to attract FDI, analyze characteristics of FDI originating in developing countries, and examine the experience of foreign investors in countries affected by conflict and fragility. Three key features of this Global Investment Competitiveness report distinguish it from other publications on FDI. First, its insights are based on a combination of first-hand perspectives of investors, extensive analysis of available data and evidence, and international good practices in investment policy design and implementation. Secondly, rather than exploring broad FDI trends, the report provides detailed and unique analysis of FDI depending on its motivation, sector, geographic origin and destination, and phase of investment. Thirdly, the report offers practical and actionable recommendations to policymakers in developing countries wishing to reform their business climates for increased investment competitiveness. As such, the report is meant to complement other knowledge products of the World Bank Group focused even more explicitly on country-level data, detailed reform diagnostics, and presentation of best practices. We are confident this report will bring value and fresh perspectives to a variety of audiences. To governments and policymakers, including investment promotion professionals, the report offers direct insights into the role of government policies and actions in investors’ decision-making. To foreign investors and site location consultants, the report provides information on FDI trends and drivers across sectors and geographies. For academic audiences, the new datasets on investment incentives and FDI motivations enables opportunities for additional research and analysis. Lastly, for development assistance providers and other stakeholders, the report highlights key approaches for maximizing FDI’s benefits for development.

Download or read book Tierra Vacante en Ciudades Latinoamericanas written by Nora Clichevsky and published by . This book was released on 2002 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Vacant urban land--the product of land market activity, the actions of private agents, and the policies of public agents--is an important challenge for policy makers. Vacant lots on the urban fringe and in central and interstitial areas have affected growth patterns in Latin America. Contributors to this book analyze the problems and opportunities related to vacant urban land in five cities: Buenos Aires, Argentina; Rio de Janeiro, Brazil; Quito, Ecuador; Lima, Perú; and San Salvador, El Salvador.

Download or read book The North American Mosaic written by Commission for Environmental Cooperation (Montréal, Québec). Secretariat and published by . This book was released on 2001 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: The North American Mosaic has four overarching features. First, it is, to the extent feasible, based on comparable information on the status and trends of major indicators of the state of the environment in Canada,Mexico, and the United States. Second, the report confirms that these three countries together make up an incredibly complex, dynamic, and interconnected ecosystem in which humans play a dominant and decisive role. Third, the report raises important and sometimes disquieting questions concerning the sustainability of some current trends. Finally, the report is a reminder that our economic, social, and physical well-being are utterly dependent on the life-sustaining services provided by nature. This report emphasizes the importance of developing mutually compatible economic, social, and environmental goals and policies across the three-country region.

Download or read book Tax Challenges Arising from Digitalisation Interim Report 2018 written by Collectif and published by OECD. This book was released on 2018-05-29 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

Download or read book Copiar el ed n written by María Berríos and published by . This book was released on 2006 with total page 662 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analyzes the evolution of contemporary art in Chile from 1973 to 2007. This edition reproduces more than 500 color images of works by 74 contemporary artists (selected by editor Mosquera) including names such as: Juan Downey, Carlos Arias, (Santiago, Chile, 1964); Juan Castillo, (Antofagasta, 1952); Eugenio Dittborn, (Santiago, Chile, 1943); Paz Errzuriz, (Santiago, Chile, 1944); Volupsa Jarpa, (Rancagua, 1971); Carlos Leppe, (Santiago, Chile, 1952); and Carolina Ruff, (Santiago, Chile, 1973), as well as younger generation artists. The artists are presented in alphabetical order with brief introductory texts. Each reproduced work is rigorously documented with a caption that, in addition to providing the technical data offers the reader a description of the work for better comprehension. Six essays by noted critics and art historians: Guillermo Machuca, Mar̕a Berr̕os, Justo Pastor Mellado, Catalina Mena, Nelly Richard y Adriana V̀lads (description provided by vendor).

Download or read book Law and Practice of Investment Treaties written by Andrew Paul Newcombe and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 644 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book focuses on the substantive protections accorded to investors and investments and on the variations among jurisdictions. Among the many specific issues and topics that arise in the course of the discussion are the following: - problems of transparency and conflict of interest; - the recent growth in IIAs between and among developing nations; - the effect of new model bilateral investment treaties (BITs); - the ability of non-disputing parties to participate in investor-state arbitration; - theories of the interaction of foreign direct investment (FDI) and BITs; - investor-state arbitration as an evasion of public regulatory authority; - the role of investment funds in international investment; - 'fork in the road' provisions; and - institutional versus ad hoc arbitration. International business and other investors will greatly appreciate the in-depth information and insightful guidance in this solidly useful book. It will also be welcomed by jurists and students as a significant milestone in the development of principles in a quickly growing field of practice that is still plagued with inconsistencies.

Download or read book Soci t s Transnationales written by United Nations Conference on Trade and Development. Programme on Transnational Corporations and published by New York : United Nations. This book was released on 1993 with total page 744 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Governing the Metropolis written by Eduardo Rojas and published by David Rockefeller Center for Latin American Studies. This book was released on 2008 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores key metropolitan management issues, presents practical principles of good governance as they apply to the metropolis, and unfolds cases of institutional and programmatic arrangements to tackle such issues.

Download or read book Food and Agricultural Development written by United States. Agency for International Development and published by . This book was released on 1982 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Policy Framework for Investment written by OECD and published by OECD Publishing. This book was released on 2006-05-11 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Drawing on good practices from OECD and non-OECD countries, the Framework proposes a set of questions for governments to consider in ten policy fields as critically important for the quality of a country’s environment for investment.

Download or read book EC Tax Review written by and published by . This book was released on 2002 with total page 728 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 999 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.

Download or read book Territorial vs Worldwide Corporate Taxation written by Ms.Thornton Matheson and published by International Monetary Fund. This book was released on 2013-10-03 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global investment patterns mean that effective taxation of foreign investors is of increasing importance to the economies of lower income countries. It is thus of considerable concern that the historical framework for cross-border income tax arrangements is not always well suited to allow low-income countries (LICs) effectively to generate tax revenues from profits on foreign direct investment (FDI). Several aspects of this framework contribute to the problem. This paper discusses, in particular, the likely effect of a shift by major economies from the system of worldwide corporate taxation toward a territorial system on the volume, distribution, and financing of FDI, focusing on LICs. It then empirically analyzes bilateral outbound FDI data for the UK for 2002–10 to determine whether the move to territoriality made corporations more sensitive to hostcountry statutory tax rates. Supporting evidence for this hypothesis is found for FDI financed from new equity.

Download or read book The International Law of Investment Claims written by Zachary Douglas and published by Cambridge University Press. This book was released on 2009-06-11 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a codification of the principles and rules relating to the prosecution of investment claims.

Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.