Download or read book MLI Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self-contained book offers an unmatched article-by-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply. Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in-depth discussion of the following and more: how specific gaps in existing bilateral tax treaties are addressed by the MLI; positions taken by selected jurisdictions and their impact on treaties; compatibility clauses, notification clauses, opting-in mechanisms, alternative provisions, and reservations; experiences in the course of implementation of the MLI; misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI; interaction between the principal purpose test and simplified limitation on benefits; improving dispute resolution; and meaning of the phrases ‘on or after’, ‘other taxes’, and interpretational issues in entry into effect provisions. Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy-to-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.
Download or read book GloBE Rules Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2022-12-09 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.
Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Download or read book Gunsmithing Made Easy written by Bryce M. Towsley and published by Skyhorse Publishing Inc.. This book was released on 2010-10-06 with total page 161 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of America s foremost experts on gunsmithing, Bryce Towsley here provides the definitive guide for anyone interested in building or maintaining guns. He gives detailed explanations and color illustrations for just about every aspect of gun repair. Featured tutorials include: stock modifications, accuracy enhancement, weather preparation, a total rifle makeover, and much more. Beginning with shop design and maintenance, Towsley builds on the knowledge he provides until ending with directions on rifle building from scratch. For anyone interested in fixing or building guns, Towsley s book is a complete education from A to Z. Skyhorse Publishing is proud to publish a broad range of books for hunters and firearms enthusiasts. We publish books about shotguns, rifles, handguns, target shooting, gun collecting, self-defense, archery, ammunition, knives, gunsmithing, gun repair, and wilderness survival. We publish books on deer hunting, big game hunting, small game hunting, wing shooting, turkey hunting, deer stands, duck blinds, bowhunting, wing shooting, hunting dogs, and more. While not every title we publish becomes a New York Times bestseller or a national bestseller, we are committed to publishing books on subjects that are sometimes overlooked by other publishers and to authors whose work might not otherwise find a home. "
Download or read book VYAVAHARA AYURVEDA FORENSIC MEDICINE MADE EASY PART 1 written by Vd. Urvashi M Patel and published by RED'SHINE Publication. Pvt. Ltd. This book was released on with total page 206 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Yachting written by and published by . This book was released on 1982-12 with total page 188 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Yachting written by and published by . This book was released on 1982-12 with total page 188 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book PC Mag written by and published by . This book was released on 1982-08 with total page 970 pages. Available in PDF, EPUB and Kindle. Book excerpt: PCMag.com is a leading authority on technology, delivering Labs-based, independent reviews of the latest products and services. Our expert industry analysis and practical solutions help you make better buying decisions and get more from technology.
Download or read book NASA Tech Briefs written by and published by . This book was released on 1999 with total page 1004 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Spacecraft Thermal Control Technologies written by Jianyin Miao and published by Springer Nature. This book was released on 2020-08-19 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents fundamental theories, design and testing methodologies, and engineering applications concerning spacecraft thermal control systems, helping readers gain a comprehensive understanding of spacecraft thermal control systems and technologies. With abundant design methods, advanced technologies and typical applications to help them grasp the basic concepts and principles of engineering applications, it is mainly intended for engineering and technical staff engaged in spacecraft thermal control areas. The book discusses the thermal environments commonly used for space flight missions, rules and regulations for system design, thermal analysis and simulation, and thermal testing methods, as well as the design and validation of the thermal control systems for Chinese spacecraft, such as the Shenzhou spacecraft and Chang’e Lunar Lander and Rover. It also introduces them to communication and remote sensing satellites and presents advanced thermal control technologies developed in recent years, including heat transfer, heat insulation, heating, refrigeration and thermal sensor technologies. Addressing the design and validation of thermal control systems for various types of Chinese spacecraft, the book offers a valuable theoretical and practical reference guide for researchers and engineers alike.
Download or read book Advances in Cryogenic Engineering Materials written by U. Balu Balachandran and published by Springer Science & Business Media. This book was released on 2012-12-06 with total page 467 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 1999 Joint Cryogenic Engineering Conference (CEC) and International Cryogenic Materials Conference (ICMC) were held in Montreal, Quebec, Canada from July 12th to July 16th. The joint conference theme was "Cryogenics into the Next Millennium". The total conference attendance was 797 with participation from 28 countries. As with previous joint CEC and ICMC Conferences, the participants were able to benefit from the joint conference's coverage of cryogenic applications and materials and their interactions. The conference format of plenary, oral and poster presentations, and an extensive commercial exhibit, the largest in CEC-ICMC history, aimed to promote this synergy. The addition of short courses, workshops, and a discussion meeting enabled participants to focus on some of their specialties. The technical tour, organized by Suzanne Gendron, was of Hydro-Quebec's research institute laboratories near Montreal. In keeping with the conference venue the entertainment theme was Jazz, culminating in .the performance of Vic Vogel and his Jazz Big Band at the conference banquet. This 1999 ICMC Conference was chaired by Julian Cave of IREQ - Institut de recherche d'Hydro-Quebec, and the Program Chair and Vice-Chair were Michael Green of the Lawrence Berkeley National Laboratory and Balu Balachandran of the Argonne National Laboratory respectively. We especially appreciate the contributions of both the CEC and ICMC Boards and the conference managers, Centennial Conferences, under the supervision of Paula Pair and Kim Bass, in making this conference a success.
Download or read book A Collection of Technical Papers written by and published by . This book was released on 1979 with total page 694 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Multilevel Inverters written by Ersan Kabalci and published by Academic Press. This book was released on 2021-03-27 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Multilevel Inverters: Control Methods and Power Electronics Applications provides a suite of powerful control methods for conventional and emerging inverter topologies instrumentalized in power electronics applications. It introduces readers to the conventional pulse width modulation control of multilevel voltage source inverter topologies before moving through more advanced approaches including hysteresis control, proportional resonance control, and model predictive control. Later chapters survey the power electronics connection between device topologies and control methods, particularly focusing on conversion in renewable energy systems, electric vehicles, static VAR compensators and solid-state transformers. Examines modern design configurations for multilevel inverter controllers, emerging control methods, and their applications Presents detailed application examples of multilevel inverters deployed in modern and recent power electronic areas including renewable energy sources, electric vehicles, and grid management Discusses deployment and development of future power converter implementation
Download or read book MLITemp A Computer Program to Predict the Thermal Effects Associated with Hypervelocity Impact Damage to Space Station MLI written by William K. Rule and published by . This book was released on 1991 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Space Debris written by Luciano Anselmo and published by . This book was released on 2005 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Imperial Lexicon of the English Language written by John Boag and published by . This book was released on 1850 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A popular and complete English dictionary written by John Boag and published by . This book was released on 1848 with total page 790 pages. Available in PDF, EPUB and Kindle. Book excerpt:
