Download or read book Qualification of Services Under Double Tax Treaties in Brazil Open Issues After Iberdrola Case written by L. Freitas de Moraes e Castro and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyses the discussion regarding the tax assessment of withholding income tax on service fees paid from Brazil to other countries that have entered into a double tax treaty with it. Mainly, after the judicial precedent known as the Iberdrola case, the Brazilian Superior Court of Justice left without analysis several issues that may play a role against future discussions on the qualification of such income under the treaty, namely the possible application of Article 12 and Article 14 to such streams of income. Although the Iberdrola case was favourable to taxpayers, since it applied Article 7 to prevent Brazil from levying the withholding tax of service payments from Brazil to Spain, it has failed to discuss if the technical service fees would be qualified under Royalties - due to a specific protocol stating so - or Independent Personal Services - due to specific wording of the double tax treaties entered into by Brazil. Due to this short-sided view of Brazilian courts, taxpayers should be aware that the precedents on the matter so far left out important issues to be examined, which can be crucial in case of a shift of position on the subject, in the near future.
Download or read book The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention written by David Orzechowski-Zölzer and published by Kluwer Law International B.V.. This book was released on 2024-05-21 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.
Download or read book Governance and Sustainability written by David Crowther and published by Emerald Group Publishing. This book was released on 2020-10-21 with total page 178 pages. Available in PDF, EPUB and Kindle. Book excerpt: An analysis of the issues raised concerning both sustainability and governance and an investigation of approaches taken to dealing with these issues. The research has been developed by experts from around the world who each look at different issues in different contexts.
Download or read book Electricity Auctions written by Luiz Maurer and published by World Bank Publications. This book was released on 2011-07-25 with total page 181 pages. Available in PDF, EPUB and Kindle. Book excerpt: Electricity-contract auctions have been getting increased attention as they have emerged as a successful mechanism to procure new generation capacity and. This book presents a comprehensive overview of international experiences in auction design and implementation.
Download or read book Landlocked Countries in South America written by United Nations and published by United Nations Publications. This book was released on 2009 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report analyses the current state of the landlocked developing countries (LLDCs) Bolivia and Paraguay. It analyses the traditional topics: infrastructure at national level and connectivity towards adjacent countries; the recent development in international laws and treaties; and cross-border operation. The report also evaluates the level of international transport costs and the potential impact on trade. It further presents the currently induced over costs in logistic chains, which pose an additional burden to the competitiveness of the countries.
Download or read book Doing Business 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-21 with total page 241 pages. Available in PDF, EPUB and Kindle. Book excerpt: Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.
Download or read book Admissibility of Shareholder Claims Under Investment Treaties written by Gabriel Bottini and published by . This book was released on 2020 with total page 335 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses a growing problem in international law: overlapping claims before national and international jurisdictions. Its contribution is, first, to revisit two pillars of investment arbitration, i.e., shareholders' standing to claim for harm to the company's assets and the contract/treaty claims distinction. These two ideas advance interrelated (and questionable) notions of independence: firstly, independence of shareholder treaty rights in respect of the local company's national law rights and, secondly, independence of treaty claims in respect of national law claims. By uncritically endorsing shareholder standing in indirect claims and the distinctiveness of treaty claims, investment tribunals have overlooked substantive overlaps between contract and treaty claims. The book also proposes specific admissibility criteria. As opposed to strictly jurisdictional approaches to claim overlap, the admissibility approach allows consideration of a broader range of legal reasons, such as risks of multiple recovery and prejudice to third parties.
Download or read book 2006 Information and Communications for Development written by and published by World Bank Publications. This book was released on 2006-01-01 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: """The report is essential reading for policy makers, government workers, and academics pursuing the goal of equitable, sustainable development across the world."" - N. R. Narayana Murthy, Chairman and Chief Mentor Infosys Technologies Ltd. Information and communication technology (ICT) is rapidly evolving, changing rich and poor societies alike. It has become a powerful tool for participating in the global economy and for offering new opportunities for development efforts. ICT can and should advance economic growth and reduce poverty in developing countries. It has been 20 years since the first telephone operator was privatized, a little over 10 since the World Wide Web emerged, and 5 since the telecommunications bubble burst. How have the ICT sector and its role in development evolved? What have we learned? How can we move forward? Information and Communications for Development 2006: Global Trends and Policies contains lessons from both developed and developing countries. It examines the roles of the public and private sectors, identifying the challenges and the benefits of adopting and expanding ICT use. The report assesses topics essential to building an information society, including investment, access, diffusion, and country policies and strategies. Assessing what has worked, what hasn't, and why, this report is an invaluable guide for understanding how to capture the benefits of ICT around the world."
Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 425 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Download or read book Alternatives to Privatization written by David A. McDonald and published by Routledge. This book was released on 2012-04-23 with total page 495 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is a vast literature for and against privatizing public services. Those who are against privatization are often confronted with the objection that they present no alternative. This book takes up that challenge by establishing theoretical models for what does (and does not) constitute an alternative to privatization, and what might make them ‘successful’, backed up by a comprehensive set of empirical data on public services initiatives in over 40 countries. This is the first such global survey of its kind, providing a rigorous and robust platform for evaluating different alternatives and allowing for comparisons across regions and sectors. The book helps to conceptualize and evaluate what has become an important and widespread movement for better public services in the global South. The contributors explore historical, existing and proposed non-commercialized alternatives for primary health, water/sanitation and electricity. The objectives of the research have been to develop conceptual and methodological frameworks for identifying and analyzing alternatives to privatization, and testing these models against actually existing alternatives on the ground in Asia, Africa and Latin America. Information of this type is urgently required for practitioners and analysts, both of whom are seeking reliable knowledge on what kind of public models work, how transferable they are from one place to another and what their main strengths and weaknesses are.
Download or read book The Technological and Economic Future of Nuclear Power written by Reinhard Haas and published by Springer. This book was released on 2019-01-01 with total page 385 pages. Available in PDF, EPUB and Kindle. Book excerpt: This open access book discusses the eroding economics of nuclear power for electricity generation as well as technical, legal, and political acceptance issues. The use of nuclear power for electricity generation is still a heavily disputed issue. Aside from technical risks, safety issues, and the unsolved problem of nuclear waste disposal, the economic performance is currently a major barrier. In recent years, the costs have skyrocketed especially in the European countries and North America. At the same time, the costs of alternatives such as photovoltaics and wind power have significantly decreased. Contents History and Current Status of the World Nuclear Industry The Dramatic Decrease of the Economics of Nuclear Power Nuclear Policy in the EU The Legacy of Csernobyl and Fukushima Nuclear Waste and Decommissioning of Nuclear Power Plants Alternatives: Heading Towards Sustainable Electricity Systems Target Groups Researchers and students in the fields of political, economic and technical sciences Energy (policy) experts, nuclear energy experts and practitioners, economists, engineers, consultants, civil society organizations The Editors Prof. Dr. Reinhard Haas is University Professor of energy economics at the Institute of Energy Systems and Electric Drives at Technische Universität Wien, Austria. PD Dr. Lutz Mez is Associate Professor at the Department for Political and Social Sciences of Freie Universität Berlin, Germany. PD Dr. Amela Ajanovic is a senior researcher and lecturer at the Institute of Energy Systems and Electrical Drives at Technische Universität Wien, Austria.--
Download or read book World Energy Outlook 2015 written by International Energy Agency and published by . This book was released on 2015-11-25 with total page 700 pages. Available in PDF, EPUB and Kindle. Book excerpt: The precipitous fall in oil prices, continued geopolitical instability and the ongoing global climate negotiations are witness to the dynamic nature of energy markets. In a time of so much uncertainty, understanding the implications of the shifting energy landscape for economic and environmental goals and for energy security is vital. The World Energy Outlook 2015 (WEO-2015) will present updated projections for the evolution of the global energy system to 2040, based on the latest data and market developments, as well as detailed insights on the prospects for fossil fuels, renewables, the power sector and energy efficiency and analysis on trends in CO2 emissions and fossil-fuel and renewable energy subsidies.
Download or read book International Protection of Investments written by August Reinisch and published by Cambridge University Press. This book was released on 2020-07-16 with total page 1633 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book outlines the protection standards typically contained in international investment agreements as they are actually applied and interpreted by investment tribunals. It thus provides a basis for analysis, criticism, and stocktaking of the existing system of investment arbitration. It covers all main protection standards, such as expropriation, fair and equitable treatment, full protection and security, the non-discrimination standards of national treatment and MFN, the prohibition of unreasonable and discriminatory measures, umbrella clauses and transfer guarantees. These standards are covered in separate chapters providing an overview of textual variations, explaining the origin of the standards and analysing the main conceptual issues as developed by investment tribunals. Relevant cases with quotations that illustrate how tribunals have relied upon the standards are presented in depth. An extensive bibliography guides the reader to more specific aspects of each investment standard permitting the book's use as a commentary of the main investment protection standards.
Download or read book Remaking Europe written by Reinhilde Veugelers and published by . This book was released on 2017-09-30 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: How well are European firms responding to the new opportunities for growth, and in which global value chains are they developing these new activities? The policy discussion on the future of manufacturing requires an understanding of the changing role of manufacturing in Europe's growth agenda.
Download or read book Wind Vision written by U. S. Department U.S. Department of Energy and published by CreateSpace. This book was released on 2015-03-18 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a detailed roadmap of technical, economic, and institutional actions by the wind industry, the wind research community, and others to optimize wind's potential contribution to a cleaner, more reliable, low-carbon, domestic energy generation portfolio, utilizing U.S. manu-facturing and a U.S. workforce. The roadmap is intended to be the beginning of an evolving, collaborative, and necessarily dynamic process. It thus suggests an approach of continual updates at least every two years, informed by its analysis activities. Roadmap actions are identified in nine topical areas, introduced below.
Download or read book The EU s Major Electricity and Gas Utilities Since Market Liberalization written by Christian Schülke and published by Gouvernance Europeenne Et Geop. This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A major change has taken place in the company structure of the European electricity and gas markets. Since the liberalization of EU energy markets began in the 1990s, companies like E.ON, GDF Suez, EDF, Enel, and RWE have become European giants with activities in a large number of member states. The advocates of market liberalization did not expect, or intend, the emergence of a small number of large utilities that control an increasing part of the EU market. Some observers claim that liberalization has led to an oligopoly with detrimental consequences for competition. Based on extensive background research, this book presents a fact-based analysis of the changes in the European utility sector since the 1990s. Case studies of the seven largest utilities illustrate how companies adapted their strategies to the changing market environment. The author underlines diverging choices and common trends with the aim of using synergies between electricity and gas.
Download or read book Fair and Equitable Treatment written by United Nations Conference on Trade and Development and published by . This book was released on 2012 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "In recent years, the concept of fair and equitable treatment has assumed prominence in investment relations between States. While the earliest proposals that made reference to this standard of treatment for investment are contained in various multilateral efforts in the period immediately following World War II, the bulk of the State practice incorporating the standard is to be found in bilateral investment treaties which have become a central feature in international investment relations. In essence, the fair and equitable standard provides a yardstick by which relations between foreign direct investors and Governments of capital-importing countries may be assessed. It also acts as a signal from capital-importing countries, for it indicates, at the very least, a State's willingness to accommodate foreign capital on terms that take into account the interests of the investor in fairness and equity."--Provided by publisher.
