Download or read book Individuals Income Under Double Taxation Conventions written by Daniel Vitor Bellan and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 466 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
Download or read book Tax Treaty Case Law around the Globe 2019 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-07-22 with total page 412 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Download or read book New Serial Titles written by and published by . This book was released on 1995 with total page 2012 pages. Available in PDF, EPUB and Kindle. Book excerpt: A union list of serials commencing publication after Dec. 31, 1949.
Download or read book Guide to Foreign and International Legal Citations written by and published by . This book was released on 2006 with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Formerly known as the International Citation Manual"--p. xv.
Download or read book Handbook for the Foreign Investor in Brazil written by São Paulo (Brazil : State). Secretaria de Economia e Planejamento and published by . This book was released on 1977 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Access to Treaty Benefits written by Desiree Auer and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
Download or read book The Competence of the National Congress in Brazil to Decide on Policy Domains Marked by a High Degree of Technical Complexity written by Paula Santos and published by EconSciences. This book was released on 2024-01-01 with total page 213 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book delves into the intricate relationship between legislative power, and public policy efficiency, exploring their impact on the formulation and implementation of public policies in Brazil. The book adopts a mixed-method approach, combining descriptive statistics and qualitative content analysis, to shed light on this less-explored aspect of legislative functioning, investigating whether the Legislative Power in Brazil uses its competence to vote on matters of a specialized nature or delegates the rule to the Executive Power. The legislative process analyzed in this thesis is one of a Provisional Measure. This process is the most appropriate because it involves both houses of Congress and begins with the Executive branch enacting the rule. Descriptive statistics show correlations between key variables, while qualitative content analysis revealed a preference for the Legislative Power to regulate matters of technical nature rather than delegating them to specialized bodies. The book's findings underscore the importance of public trust in government actions, as both the Executive and Legislative branches need to prioritize transparency, accountability, and responsiveness to maintain public confidence in the regulatory process. Policymakers must carefully assess the context and objectives of each regulatory proposal to make informed decisions about delegation that best serve the public's interests and the government's effective functioning.
Download or read book Taxation in Latin America written by and published by . This book was released on 1970 with total page 792 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Download or read book Implementing Value Capture in Latin America written by Martim Oscar Smolka and published by Lincoln Inst of Land Policy. This book was released on 2013 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report examines a variety of specific instruments and applications in municipalities throughout the region under three categories: property taxation and betterment contributions; exactions and other direct negotiations for charges for building rights or the transfer of development rights; and large-scale approaches such as development of public land through privatization or acquisition, land readjustment, and public auctions of bonds for purchasing building rights. It concludes with a summary of lessons learned and recommends steps that can be taken in three spheres: Learn from Implementation Experiences Increase Knowledge about Theory and Practice Promote Greater Public Understanding and Participation
Download or read book National Union Catalog written by and published by . This book was released on 1982 with total page 1032 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes entries for maps and atlases.
Download or read book Workplace Solutions for Childcare written by Catherine Hein and published by International Labor Office. This book was released on 2010 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: Covers childcare centres, vouchers, subsidies, out-of-school care, parental leave and flexible working.
Download or read book General Catalogue of Printed Books written by British Museum. Department of Printed Books and published by . This book was released on 1979 with total page 946 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book ABC Pol Sci written by and published by . This book was released on 1976 with total page 562 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book ABUSO DE TRATADOS INTERNACIONAIS E A REGRA DO PRINCIPAL PURPOSE TEST written by Melody Araújo Pinto Furman and published by Arraes Editores. This book was released on 2022-09-06 with total page 159 pages. Available in PDF, EPUB and Kindle. Book excerpt: O livro estuda a regra do Principal Purpose Test (PPT), uma regra geral antiabuso que lida com planejamentos tributários internacionais. Essa regra foi proposta no âmbito do Projeto BEPS (Base Erosion and Profit Shifting) como fruto da Ação 6 do Projeto. Após uma introdução sobre os planejamentos tributários internacionais e de regras propostas ao longo dos anos para lidar com essa prática, estuda-se a regra PPT. Avalia-se o conceito, os objetivos, o alcance e os elementos estruturantes da regra PPT, bem como o status atual de adoção dessa regra nos tratados internacionais celebrados pelo Brasil.
Download or read book Ulrich s International Periodicals Directory written by Carolyn Farquhar Ulrich and published by . This book was released on 1988 with total page 1298 pages. Available in PDF, EPUB and Kindle. Book excerpt: Volume for 1947 includes "A list of clandestine periodicals of World War II, by Adrienne Florence Muzzy."
