Download or read book International Company Taxation in the Era of Information and Communication Technologies written by Anne Schäfer and published by Springer Science & Business Media. This book was released on 2007-12-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.
Download or read book International Tax Planning in the Age of Ict written by Christoph Spengel and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increased use of information and communication technologies (ICT) leads to new ways of doing business internationally. Nowadays, firm-specific intangible assets as well as services often constitute the most important factors for the creation of value. Besides, geographic distances tend to be less relevant. The main objective of international tax planning consists of minimising the effective tax rate of the whole company or group. In this paper, it is examined for several instruments of international tax planning whether new chances of minimising the effective tax rate emerge with the use of ICT and to what extent new risks occur. The analysis comprises the (re)location of a company's residence, the (re)allocation of functions and risks, the implementation of a transfer pricing system, the choice of the form and location of investments abroad as well as hybrid forms of co-operation. For each instrument, both current and non-current tax issues are considered. We conclude that, due to ICT, it is easier to make use of the international tax differential by choosing the optimal location and form of investment and by allocating functions and risks. Thus, companies can pay more attention to the tax-optimal choice between international locations and the importance of this instrument to reduce the effective tax rate is further strengthened by the use of ICT.
Download or read book Value Added Tax and Direct Taxation written by Michael Lang and published by IBFD. This book was released on 2009 with total page 1341 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.
Download or read book Taxation in a Global Digital Economy written by Ina Kerschner and published by Linde Verlag GmbH. This book was released on 2017-10-04 with total page 467 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Download or read book The Taxation of Permanent Establishments written by Sven Hentschel and published by Springer Nature. This book was released on 2021-06-26 with total page 521 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Download or read book EU Freedoms Non EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Download or read book Tax Reform in the 21st Century written by John G. Head and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 578 pages. Available in PDF, EPUB and Kindle. Book excerpt: No government can be sustained without the ability to tax its citizens. The question then arises how can a nation do so in a way that's fair and equitable to taxpayers while simultaneously promoting economic growth and providing the state with the funds it needs to adequately address the needs of its citizens? This insightful work, featuring contributions from a stellar array of international tax experts and economists, addresses the crucial, relevant issues which developed countries will confront in the early decades of the 21st century: The pursuit of tax reform. Personal tax base: income or consumption? Tax rate scale: equity and efficiency aspects. Business tax reform: structural and design issues. Interjurisdictional issues. Controlling tax avoidance.
Download or read book Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross border Context written by Sven-Eric Bärsch and published by Springer Science & Business Media. This book was released on 2012-12-13 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.
Download or read book Electronic Consumer Contracts in the Conflict of Laws written by Zheng Sophia Tang and published by Bloomsbury Publishing. This book was released on 2015-10-22 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: The second edition of this highly recommended work addresses the interaction between conflict of laws, dispute resolution, electronic commerce and consumer contracts. In addition it identifies specific difficulties that conflicts lawyers and consumer lawyers encounter in electronic commerce and proposes original approaches to balance the conflict of interest between consumers' access to justice and business efficiency. The European Union has played a leading role in this area of law and its initiatives are fully explored. It pays particular attention to the most recent development in collective redress and alternative/online dispute resolution. By adopting multiple research methods, including a comparative study of the EU and US approach; historical analysis of protective conflict of laws; doctrinal analysis of legal provisions and economic analysis of law, it provides the most comprehensive examination of frameworks in cross-border consumer contracts.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an analysis of the challenges the spread of the digital economy poses for international taxation.
Download or read book International VAT GST Guidelines written by Collectif and published by OECD. This book was released on 2017-04-12 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) has become a major source of revenue for governments around the world. Some 165 countries operated a VAT at the time of the completion of the International VAT/GST Guidelines in 2016, more than twice as many as 25 years before. As VAT continued to spread across the world, international trade in goods and services has also expanded rapidly in an increasingly globalised economy. One consequence of these developments has been the greater interaction between VAT systems, along with growing risks of double taxation and unintended non-taxation in the absence of international VAT co-ordination. The International VAT/GST Guidelines now present a set of internationally agreed standards and recommended approaches to address the issues that arise from the uncoordinated application of national VAT systems in the context of international trade. They focus in particular on trade in services and intangibles, which poses increasingly important challenges for the design and operation of VAT systems worldwide. They notably include the recommended principles and mechanisms to address the challenges for the collection of VAT on cross-border sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project). These Guidelines were adopted as a Recommendation by the Council of the OECD in September 2016.
Download or read book Use of Technology in Tax Administrations 1 written by Ms.Margaret Cotton and published by International Monetary Fund. This book was released on 2017-03-14 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt: This technical note is the first of three addressing information technology (IT) themes and issues relevant to tax administrations. This note focuses on the use of technology in tax administrations and how to develop an information technology strategic plan (ITSP). It is intended for tax administrations that are largely manual or have outdated legacy IT systems. The second note addresses how to select an IT system for core tax administrations functions. And the third note covers implementation of a commercial-off-the-shelf (COTS) system. These technical notes are primarily for use by tax administrations that have no technology to manage their core tax processes, or their technology is limited and outdated. These notes focus on core tax functions and do not address other business systems (e.g., payroll, finance, document, and asset management systems).
Download or read book Digitalization to Improve Tax Compliance Evidence from VAT e Invoicing in Peru written by Mr.Matthieu Bellon and published by International Monetary Fund. This book was released on 2019-11-01 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the impact of e-invoicing on firm tax compliance and performance using administrative tax data and quasi-experimental variation in the rollout of VAT electronic invoicing in Peru. We find that e-invoicing increases reported firm sales, purchases and value-added by over 5 percent in the first year after adoption. The impact is concentrated among smaller firms and sectors with higher rates of non-compliance, suggesting that e-invoicing enhances compliance by lowering compliance costs and strengthening deterrence. The reform’s positive effects on tax collection are hindered by shortcomings in the VAT refund mechanism in Peru, suggesting that digital tools such as e-invoicing should be complemented by other reforms to improve revenue mobilization.
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1990 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Digitalization and Taxation in Asia written by Ms. Era Dabla-Norris and published by International Monetary Fund. This book was released on 2021-09-14 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.
Download or read book Tax Administration 2021 Comparative Information on OECD and other Advanced and Emerging Economies written by OECD and published by OECD Publishing. This book was released on 2021-09-15 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Download or read book Taxing Telecommunications in Developing Countries written by Ms.Thornton Matheson and published by International Monetary Fund. This book was released on 2017-11-15 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: Developing countries apply numerous sector-specific taxes to telecommunications, whose buoyant revenues and formal enterprises provide a convenient “tax handle”. This paper explores whether there is an economic rationale for sector-specific taxes on telecommunications and, if so, what form they should take to balance the competing goals of promoting connectivity and mobilizing revenues. A survey of the literature finds that limited telecoms competition likely creates rents that could efficiently be taxed. We propose a “pecking order” of sector-specific taxes that could be levied in addition to standard income and value-added taxes, based on capturing rents and minimizing distortions. Taxes that target possible economic rents or profits are preferable, but their administrative challenges may necessitate reliance on service excises at the cost of higher consumer prices and lower connectivity. Taxes on capital inputs and consumer access, which distort production and restrict network access, should be avoided; so should tax incentives, which are not needed to attract foreign capital to tap a local market.
