Download or read book BRICS and International Tax Law written by Peter Antony Wilson and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.

Download or read book Extension in due dates and tax exemption for compensation CBDT Analysis by Taxmann s Editorial Board written by Taxmann and published by Taxmann Publications Private Limited. This book was released on 2021-06-29 with total page 11 pages. Available in PDF, EPUB and Kindle. Book excerpt: The CBDT has recently extended the due dates for certain compliances and has also announced to provide tax exemption for the expenditure incurred by the taxpayers on COVID-19 treatment. The impact of new Notifications and Circular on various time barring dates and certain compliance of Income-tax Act are discussed in this article.

Download or read book International Economic Law written by Mariela de Amstalden and published by Springer Nature. This book was released on 2024-01-13 with total page 358 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume considers novel emerging issues in international economic law, as well as new methodological approaches to more familiar topics. It brings together a diverse range of contributors from five continents, who share invaluable perspectives on a wide range of issues in international economic governance. In doing so, this volume delves deeply into some of the most challenging emerging areas in international economic law, approaching them from an interdisciplinary perspective that brings together legal, economic, and political analysis. Intended for academics and practitioners at all stages of their careers, many of the areas considered in this volume are either entirely new or are being revisited after periods of dormancy. It is our hope that these contributions will yield fresh insights into these new and “classic” areas of IEL. We consider diversity and inclusivity foundational values in IEL. The wealth of ideas showcased in this volume present us with an opportunity to appreciate different facets of originality and rigour in legal academic writing, further highlighting the range of methodological and stylistic preferences of emerging legal scholars in IEL. In June 2022, forty emerging international economic law scholars were selected to present their papers at PEPA/SIEL, where they received feedback from senior members of the SIEL community and beyond. The discussions were lively, stimulating and enriching, leading the editors of this volume to propose putting a selection of the papers into a published book.

Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.

Download or read book International Catalogue of Scientific Literature written by and published by . This book was released on 1915 with total page 1070 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Employee Equity Plans written by Mary K. Samsa and published by Kluwer Law International B.V.. This book was released on 2003-01-01 with total page 642 pages. Available in PDF, EPUB and Kindle. Book excerpt: World Law Group Series Volume 4 Although the economic downturns of 2001 and 2002 have threatened to dampen enthusiasm for employee equity participation in business enterprises, such plans continue to be offered by employers in nearly all major national jurisdictions. The time is ripe, in fact, to clarify and elucidate the legal complexities of extending such plans across borders to employees working in other countries. This is the first book to provide in-depth, country-by-country coverage of the national law issues that must be considered by an employer implementing (or considering the implementation of) a multinational employee equity plan. For each of thirty countries, International Employee Equity Plans presents a detailed survey of applicable law, trends, and customs affecting employee participation. Each chapter is written by practicing employment lawyers in that particular jurisdiction, ensuring that the critical issues, potential pitfalls, and likely changes are incisively dealt with. Among the matters described and analysed for each country are the following: the most advantageous (and disadvantageous) types of plans; relevant securities offering rules; all legal compliance steps; available exemptions and reliefs and the conditions upon which they are offered; the fine line between and¿informingand¿ and and¿advisingand¿; taxation of employee benefits and other tax rules; and the extent to which local courts will recognize foreign law in all pertinent matters. The wealth of guidance and information in this book will help many more organisations to follow the lead of those companies that have already achieved remarkable success in this important area of international business. Legal practitioners, in-house counsel, human resources executives and others involved in implementing employee equity plans have here a detailed and user-friendly handbook covering the most important jurisdictions. The World Law Group is a network of independent law firms located in most of the world's major commercial cities. Each World Law Group memebr firm has been selected for its excellent business reputation, its dept of commitment to international practice and its ability to assist other member firms in their national dealings. For more information, please visit http://www.theworldlawgroup.com.

Download or read book Essays on International Taxation written by Dhruv Sanghavi and published by Bloomsbury Publishing. This book was released on 2020-05-06 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom

Download or read book Tax Planning for International Mergers Acquisitions Joint Ventures and Restructurings written by Ansgar A. Simon and published by Kluwer Law International B.V.. This book was released on 2023-08-31 with total page 2424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.

Download or read book Current Affairs written by YCT Expert Team and published by YOUTH COMPETITION TIMES. This book was released on with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: 2022 Current Affairs Success

Download or read book Current Affairs Bulletin written by YCT Expert Team and published by YOUTH COMPETITION TIMES. This book was released on with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: 2021-22 Tokyo Paralympic Games 2020 & Tokyo Olympics 2020

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 Notes International written by and published by . This book was released on 1996 with total page 1072 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Business written by Gupta C.B. and published by S. Chand Publishing. This book was released on with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Business

Download or read book 2024 25 RRB Nursing Solved Papers and Practice Book written by YCT Expert Team and published by YOUTH COMPETITION TIMES. This book was released on with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: 2024-25 RRB Nursing Solved Papers and Practice Book 288 495 E. This book contains 24 sets of previous year’s solved papers.

Download or read book In the Wonderland of Investment for NRIs FY 2021 22 written by A.N. Shanbhag and published by Vision Books. This book was released on 2021-07-05 with total page 162 pages. Available in PDF, EPUB and Kindle. Book excerpt: Investment Opportunities and Tax Benefits for NRIs in India India is one of world’s fastest growing economies. NRIs can uniquely benefit from this growth both because of their familiarity with the country and the special investment benefits and tax concessions offered to them, with repatriation facilities. This bestselling guide provides NRIs clear, incisive and profitable insights into: ● Important investment avenues in India ● Investment opportunities in Indian shares and mutual funds ● Opportunities and benefits of investing in immovable property ● The tax haven that is India ● Highlights of relevant taxation provisions, including double taxation agreements ● How residential status impacts taxability status ● Different types of NRI incomes: what is Indian income, forex income ● Forex remittances by NRIs and FEMA provisions ● Banking options and preferentials ● Best options for NRIs planning to return to India ● Baggage rules — what comprise baggage; what attracts duty, what doesn't ● Also, NRI-related provisions of Budget '21, and much else. In effect, NRIs enjoy a "favoured son" status in India, which provides them the greenest of financial pastures. Come, find out how you can benefit from it.

Download or read book Taxmann s International Taxation Ready Reckoner India s first ready reckoner designed to simplify cross border tax complexities with practical guidance case studies etc written by CA Daksha Baxi and published by Taxmann Publications Private Limited. This book was released on 2024-09-23 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is India's first 'ready reckoner' specifically focused on the complexities of international taxation and cross-border transactions. It provides comprehensive coverage of essential topics, including the basic provisions of India's taxation scheme, the concept of residence, and the crucial role of Double Taxation Avoidance Agreements (DTAA). The book also discusses the interaction between DTAAs and the Income-tax Act, guiding how to read a DTAA, determine eligibility, and resolve conflicts between a DTAA and domestic tax laws. This handbook is helpful for tax professionals, legal advisors, tax practitioners, tax officers and businesses dealing with cross-border transactions, such as payments to non-residents, transactions involving non-residents, digital transactions, and the withholding tax obligations of residents. The second edition has been updated with the latest amendments from the Finance (No. 2) Act, 2024, and features expanded discussions, additional material, more case studies, and judicial precedents, providing in-depth analysis and practical insights into international taxation. The Present Publication is the 2nd Edition and has been amended by the Finance (No. 2) Act, 2024. This book has been authored by CA Daksha Baxi & Adv. Surajkumar Shetty, with the following noteworthy features: • [Comprehensive Coverage] Covering a broad spectrum of topics, the book details the basic provisions, residential status, the role and application of Double Taxation Avoidance Agreements (DTAA), and their interaction with the Income-tax Act. It provides a step-by-step guide on how to read a DTAA, determine eligibility, and resolve conflicts between DTAA and the Income-tax Act • [In-depth DTAA Analysis] It examines multiple DTAAs to demonstrate how tax implications can vary across treaties or remain consistent, providing clear explanations for these outcomes. This detailed analysis helps readers understand the nuanced application of DTAAs in various cross-border scenarios • [Detailed Chapter Organisation] The chapters are organised to cover different types of income and transactions, such as rental income, business income, dividends, interest, royalties, technical services, capital gains, employment, and more. This structure brings together all relevant provisions of the Income-tax Act, including appropriate cross-references, making navigation straightforward for users • [Taxability Evaluation] The book provides comprehensive guidance on evaluating the taxability of cross-border transactions using the Income-tax Act, DTAA and references to rules, forms, circulars, and landmark judicial precedents. This holistic approach equips readers to assess tax implications accurately and effectively • [Practical Guidance for Advisors] Throughout the book, notes provide valuable insights into how advisors should approach transactions, the investigations required, and the application of the principles of the Income-tax Act and DTAA. This practical advice helps professionals offer sound, informed guidance on cross-border tax matters • [Simplified Explanations] Complex concepts such as Place of Effective Management (PoEM), Permanent Establishment (PE), and business connections are explained in simple language, supplemented with practical examples and judicial precedents. Relevant statutory texts are reproduced verbatim for easy reference, aiding readers in understanding and applying the law • [Special Focus on Investment Structures] The book discusses the taxation of Foreign Portfolio Investors and various investment funds, including Alternative Investment Funds (AIFs), Infrastructure Investment Trusts (InvITs), Real Estate Investment Trusts (REITs), and Securitisation Trusts. It specifically addresses scenarios involving non-resident investors in these structures • [Litigation and Compliance] It provides an overview of provisions related to litigation proceedings under the Income-tax Act, Mutual Agreement Procedures (MAP) under DTAA, the Authority for Advance Rulings (AAR), equalisation levy, transfer pricing provisions, general anti-avoidance rules (GAAR), and special provisions for International Financial Services Centres (IFSC). This comprehensive coverage ensures professionals are well-prepared for compliance and dispute resolution • [Illustrative Case Studies] To enhance practical understanding, the book includes numerous illustrations, practical examples, and comprehensive case studies. These are designed to cover various aspects of cross-border transactions, providing readers with insights into the subtleties and practical challenges involved The structure and layout of the book is as follows: • [25 Well-structured Chapters] dedicated to a specific area of international taxation, including detailed discussions on relevant provisions and practical guidance • [Cross-references] to other chapters where necessary, ensuring clarity and ease of navigation and enhancing the reader's ability to understand complex interrelationships within tax laws • [Appendix] includes formats for relevant forms, updates on withholding tax rates, summaries of abbreviations, and comprehensive lists of withholding tax rates under India's existing DTAAs, serving as a practical toolkit for professionals The contents of the book are as follows: • Tax System for Non-Residents in India – An Overview • Tax Treaties • Setting Up a Business in India • Classification of Income • Determining Eligibility to Claim Benefits of DTAA • Taxation of Rental Income • Taxation of Business Income • Taxation of Dividend Income • Taxation of Interest Income • Taxation of Royalty Income • Taxation of Income from Fees for Technical Services • Taxation of Capital Gains • Taxation of Employment Income • Taxation of Non-Resident Indian • Taxation of Foreign Portfolio Investors • Taxation of AIFs, REITs, InvITs, Securitisation Trust • Transactions Attracting Transfer Pricing Regulations • Business Reorganisations • Discontinuance of Business and Dissolution of Indian Company • Foreign Tax Credit • Making Payments to NRs & Obtaining Lower Withholding Certificate • Assessments, Appeals and Dispute Resolution • General Anti-Avoidance Rules • Miscellaneous • Case Study to Determine Taxability of NR, under the IT Act & DTAA

Download or read book International Tax Disputes written by Hans Mooij and published by Edward Elgar Publishing. This book was released on 2024-06-05 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bringing together global experts from diverse legal backgrounds, this comprehensive book offers a rigorous analysis of the complexity of resolving and preventing international tax disputes, covering arbitration, mediation, and dispute management. Presenting an authoritative overview of international tax disputes, this book will be indispensable to practitioners in corporate and international tax, controversy and dispute specialists, and investment arbitration lawyers.