Download or read book International Tax Cooperation written by Luzius U. Cavelti and published by Stämpfli Verlag. This book was released on 2016-10-27 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Why is international cooperation on taxation so difficult to achieve? The problems in international taxation arise from a sovereignty conflict between the country in which the income originates (source country) and the country in which the recipient of the income resides (residence country). This book explores the equally valid sovereign tax claims of source and of residence countries and highlights the incompatibility of these concurrent tax claims. The resulting incoherence between source and residence countries distorts taxation of cross-border income to a point where it not only creates discriminations but challenges the fundamental principles of international taxation in itself. This is an essential dilemma of international tax policy. And yet, given the profound role the power to tax plays in exercising sovereignty, are governments able, or even willing, to eliminate this essential dilemma?

Download or read book The Concept of Permanent Establishment in the Insurance Business written by Daniele Frescurato and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.

Download or read book International Taxation of Cloud Computing written by Alexander Weisser and published by Éditions juridiques libres / Freier juristischer Verlag. This book was released on 2020-10-07 with total page 594 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profit is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.

Download or read book Recueil Des Cours Collected Courses 1936 written by Academie De Droit International De La Ha and published by Martinus Nijhoff Publishers. This book was released on 1973-07-01 with total page 730 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Droit fiscal international written by Daniel de Vries Reilingh and published by . This book was released on 2022 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Encyclopedia of Comparative Law written by K. Zweigert and published by Brill Archive. This book was released on 2003-01-01 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: No Sales rights in German-speaking countries, Eastern Europe, Portugal, Spain, Italy, Greece, South and Central America

Download or read book Recueil Des Cours Collected Courses 1939 written by Academie De Droit International De La Ha and published by Martinus Nijhoff Publishers. This book was released on 1968-12-01 with total page 588 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Bulletin for International Fiscal Documentation written by International Bureau of Fiscal Documentation and published by . This book was released on 1977 with total page 628 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Recueil Des Cours Collected Courses 1969 written by Academie De Droit International De La Ha and published by Martinus Nijhoff Publishers. This book was released on 1970-12-01 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Academy is a prestigious international institution for the study and teaching of Public and Private International Law and related subjects. The work of the Hague Academy receives the support and recognition of the UN. Its purpose is to encourage a thorough and impartial examination of the problems arising from international relations in the field of law. The courses deal with the theoretical and practical aspects of the subject, including legislation and case law. All courses at the Academy are, in principle, published in the language in which they were delivered in the "Collected Courses of the Hague Academy of International Law .

Download or read book Annuaire suisse de droit international written by and published by . This book was released on 1985 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Fiscal Federalism in Switzerland written by Bernard Dafflon and published by World Bank Publications. This book was released on 2005 with total page 78 pages. Available in PDF, EPUB and Kindle. Book excerpt: Its highly fragmented structure of local governments and serious horizontal fiscal imbalances make Switzerland a surprisingly powerful model for Eastern European countries that are currently facing the challenge of fiscal decentralization. In spite of the substantial differences in the tradition and current practice of intergovernmental fiscal relations, transition economies may learn valuable lessons from the Swiss case in the fields of direct democracy, horizontal cooperation, expenditure and revenue assignment, and fiscal discipline. Among other conclusions, the authors suggest that subnational authorities can effectively fend off recentralization attempts of the central government if they engage in spontaneous cooperation to enhance the efficiency of public service provision. Together with an adequate fiscal equalization scheme, interjurisdictional cooperation also permits the reconciliation of the objective of an increasing devolution of powers with the existing regional disparities. The authors also show that the principle of subsidiarity can best be safeguarded by anchoring the expenditure and revenue powers of subnational governments in the constitution or in a similarly strong law. With regard to fiscal discipline, the combination of a "golden rule" with direct democratic instruments of budget control is proven to be successful in enhancing the accountability of local politicians toward their constituencies.

Download or read book Swiss Public Administration written by Andreas Ladner and published by Springer. This book was released on 2018-08-07 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: Swiss citizens approve of their government and the way democracy is practiced; they trust the authorities and are satisfied with the range of services Swiss governments provide. This is quite unusual when compared to other countries. This open access book provides insight into the organization and the functioning of the Swiss state. It claims that, beyond politics, institutions and public administration, there are other factors which make a country successful. The authors argue that Switzerland is an interesting case, from a theoretical, scientific and a more practice-oriented perspective. While confronted with the same challenges as other countries, Switzerland offers different solutions, some of which work astonishingly well.

Download or read book Taxation in Switzerland written by Harvard Law School. International Tax Program and published by . This book was released on 1976 with total page 1456 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Collected courses of the Hague Academy of International Law written by Hague Academy of International Law and published by . This book was released on 1970 with total page 614 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International law review written by and published by . This book was released on 1978 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Publications of the International Bureau of Fiscal Documentation written by International Bureau of Fiscal Documentation and published by . This book was released on 1970 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Roster of International Arbitrators written by and published by . This book was released on 2010 with total page 1284 pages. Available in PDF, EPUB and Kindle. Book excerpt: