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Book Tax Sovereignty in the BEPS Era

    Book Details:
  • Author : Sergio André Rocha
  • Publisher : Kluwer Law International B.V.
  • Release : 2016-04-24
  • ISBN : 9041167080
  • Pages : 378 pages

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.

Book International Taxation of Income from Services under Double Taxation Conventions

Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

Book ABUSO DE TRATADOS INTERNACIONAIS E A REGRA DO PRINCIPAL PURPOSE TEST

Download or read book ABUSO DE TRATADOS INTERNACIONAIS E A REGRA DO PRINCIPAL PURPOSE TEST written by Melody Araújo Pinto Furman and published by Arraes Editores. This book was released on 2022-09-06 with total page 159 pages. Available in PDF, EPUB and Kindle. Book excerpt: O livro estuda a regra do Principal Purpose Test (PPT), uma regra geral antiabuso que lida com planejamentos tributários internacionais. Essa regra foi proposta no âmbito do Projeto BEPS (Base Erosion and Profit Shifting) como fruto da Ação 6 do Projeto. Após uma introdução sobre os planejamentos tributários internacionais e de regras propostas ao longo dos anos para lidar com essa prática, estuda-se a regra PPT. Avalia-se o conceito, os objetivos, o alcance e os elementos estruturantes da regra PPT, bem como o status atual de adoção dessa regra nos tratados internacionais celebrados pelo Brasil.

Book Welcome to the United States

Download or read book Welcome to the United States written by and published by . This book was released on 2007 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Free Speech  A Very Short Introduction

Download or read book Free Speech A Very Short Introduction written by Nigel Warburton and published by OUP Oxford. This book was released on 2009-02-26 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'I disapprove of what you say, but I will defend to the death your right to say it' This slogan, attributed to Voltaire, is frequently quoted by defenders of free speech. Yet it is rare to find anyone prepared to defend all expression in every circumstance, especially if the views expressed incite violence. So where do the limits lie? What is the real value of free speech? Here, Nigel Warburton offers a concise guide to important questions facing modern society about the value and limits of free speech: Where should a civilized society draw the line? Should we be free to offend other people's religion? Are there good grounds for censoring pornography? Has the Internet changed everything? This Very Short Introduction is a thought-provoking, accessible, and up-to-date examination of the liberal assumption that free speech is worth preserving at any cost. ABOUT THE SERIES: The Very Short Introductions series from Oxford University Press contains hundreds of titles in almost every subject area. These pocket-sized books are the perfect way to get ahead in a new subject quickly. Our expert authors combine facts, analysis, perspective, new ideas, and enthusiasm to make interesting and challenging topics highly readable.

Book Principles for Building Resilience

Download or read book Principles for Building Resilience written by Reinette Biggs and published by Cambridge University Press. This book was released on 2015-04-02 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reflecting the very latest research, this book provides an in-depth review of the role of resilience in the management of social-ecological systems and the ecosystem services they provide. Leaders in the field outline seven principles for building resilience in social-ecological systems, examining how these can be applied to advance sustainability.

Book The BRICS and the Future of Global Order

Download or read book The BRICS and the Future of Global Order written by Oliver Stuenkel and published by Rowman & Littlefield. This book was released on 2020-02-03 with total page 273 pages. Available in PDF, EPUB and Kindle. Book excerpt: The transformation of the BRIC acronym from an investment term into a household name of international politics and into a semi-institutionalized political outfit (called BRICS, with a capital ‘S’), is one of the defining developments in international politics in the past decades. While the concept is now commonly used in the general public debate and international media, there has not yet been a comprehensive and scholarly analysis of the history of the BRICS term. The BRICS and the Future of Global Order, Second Edition offers a definitive reference history of the BRICS as a term and as an institution—a chronological narrative and analytical account of the BRICS concept from its inception in 2001 to the political grouping it is today. In addition, it analyzes what the rise of powers like Brazil, Russia, India, China, and South Africa means for the future of global order. Will the BRICS countries seek to establish a parallel system with its own distinctive set of rules, institutions, and currencies of power, rejecting key tenets of liberal internationalism, are will they seek to embrace the rules and norms that define today’s Western-led order?

Book Crude Existence

Download or read book Crude Existence written by Kristin Reed and published by Univ of California Press. This book was released on 2009-11-15 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: After decades of civil war and instability, the African country of Angola is experiencing a spectacular economic boom thanks to its most valuable natural resource: oil. Focusing on the everyday realities of people living in the extraction zones, Reed explores the exclusion, degradation, and violence that are the fruits of petrocapitalism in Angola.

Book Enforcing the Rule of Law

Download or read book Enforcing the Rule of Law written by Enrique Peruzzotti and published by University of Pittsburgh Pre. This book was released on 2006-04-07 with total page 377 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reports of scandal and corruption have led to the downfall of numerous political leaders in Latin America in recent years. What conditions have developed that allow for the exposure of wrongdoing and the accountability of leaders? Enforcing the Rule of Law examines how elected officials in Latin American democracies have come under scrutiny from new forms of political control, and how these social accountability mechanisms have been successful in counteracting corruption and the limitations of established institutions. This volume reveals how legal claims, media interventions, civic organizations, citizen committees, electoral observation panels, and other watchdog groups have become effective tools for monitoring political authorities. Their actions have been instrumental in exposing government crime, bringing new issues to the public agenda, and influencing or even reversing policy decisions. Enforcing the Rule of Law presents compelling accounts of the emergence of civic action movements and their increasing political influence in Latin America, and sheds new light on the state of democracy in the region.

Book Rio 2016

    Book Details:
  • Author : Andrew Zimbalist
  • Publisher : Brookings Institution Press
  • Release : 2017-09-12
  • ISBN : 0815732465
  • Pages : 166 pages

Download or read book Rio 2016 written by Andrew Zimbalist and published by Brookings Institution Press. This book was released on 2017-09-12 with total page 166 pages. Available in PDF, EPUB and Kindle. Book excerpt: " A clear-eyed, critical examination of the social, political, and economic costs of hosting the 2016 summer Olympics The selection of Rio de Janeiro as the site of the summer 2016 Olympic Games set off jubilant celebrations in Brazil—and created enormous expectations for economic development and the advancement of Brazil as a major player on the world stage. Although the games were held without major incident, the economic, environmental, political, and social outcomes for Brazil ranged from disappointing to devastating. Corruption scandals trimmed the fat profits that many local real estate developers had envisioned, and the local government was driven into bankruptcy. At the other end of the economic spectrum, some 77,000 residents of Rio's poorest neighborhoods—the favelas—were evicted and forced to move, in many cases as far as 20 or 30 miles to the west. Hosting the games ultimately cost Brazil $20 billion, with little positive to show for the investment. Rio 2016 assembles the views of leading experts on Brazil and the Olympics into a clear-eyed assessment of the impact of the games on Brazil in general and on the lives of Cariocas, as Rio's residents are known. Edited by sports economist Andrew Zimbalist, the other contributors include Juliana Barbassa, Jules Boykoff, Jamil Chade, Stephen Essex, Renata Latuf, and Theresa Williamson. "

Book Mean Baby

Download or read book Mean Baby written by Selma Blair and published by Vintage. This book was released on 2023-05-09 with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt: Selma Blair has played many roles: Ingenue in Cruel Intentions. Preppy ice queen in Legally Blonde. Muse to Karl Lagerfeld. Advocate for the multiple sclerosis community. But before all of that, Selma was known best as … a mean baby. In a memoir that is as wildly funny as it is emotionally shattering, Blair tells the captivating story of growing up and finding her truth. "Blair is a rebel, an artist, and it turns out: a writer."—Glennon Doyle, Author of the #1 New York Times Bestseller Untamed and Founder of Together Rising The first story Selma Blair Beitner ever heard about herself is that she was a mean, mean baby. With her mouth pulled in a perpetual snarl and a head so furry it had to be rubbed to make way for her forehead, Selma spent years living up to her terrible reputation: biting her sisters, lying spontaneously, getting drunk from Passover wine at the age of seven, and behaving dramatically so that she would be the center of attention. Although Selma went on to become a celebrated Hollywood actress and model, she could never quite shake the periods of darkness that overtook her, the certainty that there was a great mystery at the heart of her life. She often felt like her arms might be on fire, a sensation not unlike electric shocks, and she secretly drank to escape. Over the course of this beautiful and, at times, devasting memoir, Selma lays bare her addiction to alcohol, her devotion to her brilliant and complicated mother, and the moments she flirted with death. There is brutal violence, passionate love, true friendship, the gift of motherhood, and, finally, the surprising salvation of a multiple sclerosis diagnosis. In a voice that is powerfully original, fiercely intelligent, and full of hard-won wisdom, Selma Blair’s Mean Baby is a deeply human memoir and a true literary achievement.

Book The Takeover of Social Policy by Financialization

Download or read book The Takeover of Social Policy by Financialization written by Lena Lavinas and published by Springer. This book was released on 2017-03-25 with total page 233 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book critically addresses the model of social inclusion that prevailed in Brazil under the rule of the Workers Party from the early 2000s until 2015. It examines how the emergence of a mass consumer society proved insufficient, not only to overcome underdevelopment, but also to consolidate the comprehensive social protection system inherited from Brazil’s 1988 Constitution. By juxtaposing different theoretical frameworks, this book scrutinizes how the current finance-dominated capitalism has reshaped the role of social policy, away from rights-based decommodified benefits and towards further commodification. This constitutes the Brazilian paradox: how a center-left government has promoted and boosted financialization through a market incorporation strategy using credit as a lever for expanding financial inclusion. In so doing, it has pushed the subjection of social policy further into the logic of financial markets.

Book An Introduction to Online Platforms and Their Role in the Digital Transformation

Download or read book An Introduction to Online Platforms and Their Role in the Digital Transformation written by OECD and published by OECD Publishing. This book was released on 2019-05-13 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report contains detailed profiles of twelve of the world’s leading platform companies and derives insights from those profiles about what platforms actually do, how they do it, and why they succeed financially.

Book Corrupt Cities

Download or read book Corrupt Cities written by and published by World Bank Publications. This book was released on 2000 with total page 180 pages. Available in PDF, EPUB and Kindle. Book excerpt: Much of the devastation caused by the recent earthquake in Turkey was the result of widespread corruption between the construction industry and government officials. Corruption is part of everyday public life and we tend to take it for granted. However, preventing corruption helps to raise city revenues, improve service delivery, stimulate public confidence and participation, and win elections. This book is designed to help citizens and public officials diagnose, investigate and prevent various kinds of corrupt and illicit behaviour. It focuses on systematic corruption rather than the free-lance activity of a few law-breakers, and emphasises practical preventive measures rather than purely punitive or moralistic campaigns.

Book Inclusion Matters

Download or read book Inclusion Matters written by World Bank and published by World Bank Publications. This book was released on 2013-11-26 with total page 301 pages. Available in PDF, EPUB and Kindle. Book excerpt: Social inclusion is on the agenda of governments, policymakers, and nonstate actors around the world. Underpinning this concern is the realization that despite progress on poverty reduction, some people continue to feel left out. This report aims to unpack the concept of social inclusion and understand better how policies can be designed to further inclusion. First, the report offers a definition of social inclusion as the "process of improving the terms for individuals and groups to take part in society." It unpacks different domains of society that excluded groups and individuals are at particular risk of being left out of -- markets, services, and spaces. Second, the report discusses the most important global mega-trends such as migration, climate chnage, and aging of societies, which will impact challenges and opportunities for inclusion. Finally, it argues that despite these challenges, change towards inclusion is possible and offers examples of inclusionary policies.

Book Patrons  Clients and Policies

Download or read book Patrons Clients and Policies written by Herbert Kitschelt and published by Cambridge University Press. This book was released on 2007-03-29 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: A study of patronage politics and the persistence of clientelism across a range of countries.

Book The National union catalog  1968 1972

Download or read book The National union catalog 1968 1972 written by and published by . This book was released on 1973 with total page 662 pages. Available in PDF, EPUB and Kindle. Book excerpt: