Download or read book Substance 2 0 aligning international tax planning with today s business realities written by Axel Smits and published by . This book was released on 2012 with total page 927 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Substance aligning international tax planning with today s business realities written by Axel Smits and published by . This book was released on 2009 with total page 447 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book Global Trends 2040 written by National Intelligence Council and published by Cosimo Reports. This book was released on 2021-03 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.
Download or read book International Business Taxation written by Sol Picciotto and published by Praeger. This book was released on 1992-03-02 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.
Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 249 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Download or read book Current Challenges in Revenue Mobilization Improving Tax Compliance written by International Monetary Fund and published by International Monetary Fund. This book was released on 2015-01-29 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper addresses core challenges that all tax administrations face in dealing with noncompliance—which are now receiving renewed attention. Long a priority in developing countries, assuring strong compliance has acquired greater priority in countries facing intensified revenue needs, and is critical for fairness and statebuilding. Series: Policy Papers
Download or read book Taxation in Ghana a Fiscal Policy Tool for Development written by Dr. George Appiah-Sokye and published by AuthorHouse. This book was released on 2021-07-01 with total page 860 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first edition of this book-Taxation in Ghana: A Fiscal Policy Tool for Development- is the product of considerable tax research from 1943 to 2018, spanning a period of 75 years and grounded in knowledge and concepts; as well as, applications through an extended period of tax practice, teaching and learning; combined with international exposure. A lot of insights have been illuminated based on lessons learned and drawn from other countries, including the United States of America to enrich the contents. Against the backdrop of the dynamic nature of taxation and fiscal policy. Most of the existing taxation books in Ghana focused on tax practice. So, the purpose of this book is to bridge the taxation scholarship gap. In addition to traditionally-treated topics in most taxation books in Ghana, the novelty in this book is the inclusion of important topics on tax planning, tax reforms, and tax administration, and many more. As a result, specific recommendations have been proffered for the consideration of policy makers in developing countries. References and Acts of Parliament; supported by appendices have been provided for further studies on the subject. A true story of the first major oil discovery in Ghana by Mr. George Yaw Owusu with M. Rutledge McCall published 2017 in the United States of America: In Pursuit of JUBILEE was used to enrich the discussion on petroleum (Oil and Gas) in Chapter 48 of this textbook. Additionally, Apostle Professor Opoku Onyinah of the Church of Pentecost has been presented for his phenomenal transformational leadership in Africa in Chapter 66. The book has been designed for: (1) Individual study, (2) Group study, (3) Lecture material, (4) Policy Manual, and (5) library or reference.
Download or read book Applying the Arm s Length Principle to Intra group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Download or read book Tax Inequality and Human Rights written by Philip Alston and published by Oxford University Press, USA. This book was released on 2019 with total page 608 pages. Available in PDF, EPUB and Kindle. Book excerpt: Nikki Reisch / Taxation and human rights : mapping the landscape -- Olivier de Schutter / Taxing for the realization of economic, social, and cultural rights -- Sandra Fredman / Taxation as a human rights issue : gender and substantive equality -- Mitchell Kane / Tax and human rights : the moral valence of entitlements to tax, sovereignty, and collectives -- Allison Christians / The search for human rights in tax -- Alex Cobham / Procuring profit-shifting : the state role in tax avoidance -- Niko Lusiani and Mary Cosgrove / A strange alchemy : embedding human rights into tax policy spillover assessments -- Annet Wanyana Oguttu and Monica Iyer / Tax abuse and implications for human rights in Africa -- Michael Lennard / Some aspects of the architecture of international tax reform (and their human rights-related consequences) -- Miranda Stewart / Transparency, tax, and human rights : what is the purpose of transparency? -- Reuven Avi-Yonah and Gianluca Mazzoni / Taxation and human rights : a delicate balance -- Joshua Blank / Corporate tax privacy and human rights -- Arthur Cockfield / How countries should share tax information -- Tracy Kaye / United States' responsibility to promote financial transparency -- Dan Shaviro / Interrogating the relationship between "legally defensible" tax planning and social justice -- Matti Ylonen / Who's to blame for the money drain? corporate power and corruption as competing narratives for lost resources -- Matti Kohonen, Radhika Sarin, Troels Boerrild, and Ewan Livingston / Creating a human rights framework for mapping and addressing corporate tax abuses -- Celine Braumann / ECHR litigation as a tool for tax justice in Europe -- Kathleen Lahey / "Tax cuts for growth" v. "Taxing for equality" Using human rights to combat gender inequalities, poverty, and income inequalities in fiscal laws -- Bridget J. Crawford and Carla Spivack / Tampons are not a luxury : discriminatory taxes and human rights norms -- Andre Smith / Recent cases of regressive and racially disparate taxation -- Beverly Moran / Labor, capital, and human rights -- Michael Hanni and Ricardo Martner / Inequality, taxation, and public transfers in Latin America -- Daniel Hemel / Basic income as a human right? -- Philip Alston / Social protection as a human right
Download or read book Government Finance Statistics Manual 2014 written by Mrs.Sage De Clerck and published by International Monetary Fund. This book was released on 2015-03-10 with total page 470 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2007–09 international financial crisis underscored the importance of reliable and timely statistics on the general government and public sectors. Government finance statistics are a basis for fiscal analysis and they play a vital role in developing and monitoring sound fiscal programs and in conducting surveillance of economic policies. The Government Finance Statistics Manual 2014 represents a major step forward in clarifying the standards for compiling and presenting fiscal statistics and strengthens the worldwide effort to improve public sector reporting and transparency.
Download or read book Taxation and Value Creation written by Werner C. Haslehner and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
Download or read book The Greenhouse Gas Protocol written by and published by World Business Pub.. This book was released on 2004 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The GHG Protocol Corporate Accounting and Reporting Standard helps companies and other organizations to identify, calculate, and report GHG emissions. It is designed to set the standard for accurate, complete, consistent, relevant and transparent accounting and reporting of GHG emissions.
Download or read book OECD G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2016-08-26 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.
Download or read book Fiscal Analysis of Resource Industries written by Ms.Oana Luca and published by International Monetary Fund. This book was released on 2016-02-24 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt: This manual introduces key concepts and methodology used by the Fiscal Affairs Department (FAD) in its fiscal analysis of resource industries (FARI) framework. Proper evaluation of fiscal regimes for extractive industries (EI) requires economic and financial analysis at the project level, and FARI is an analytical tool that allows such fiscal regime design and evaluation. The FARI framework has been primarily used in FAD’s advisory work on fiscal regime design: it supports calibration of fiscal parameters, sensitivity analysis, and international comparisons. In parallel to that, FARI has also evolved into a revenue forecasting tool, allowing IMF economists and government officials to estimate the composition and timing of expected revenue streams from the EI sector, analyze revenue management issues (including quantification of fiscal rules), and better integrate the EI sector in the country macroeconomic frameworks. Looking forward, the model presents a useful tool for revenue administration practitioners, allowing them to compare actual, realized revenues with model results in tax gap analysis.
Download or read book Transfer Pricing Developments Around the World 2018 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2018-08-21 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers seven topic-based papers prepared by international experts on transfer pricing. Greatly helping to define where the line should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures, this book encompasses the following topics: • global transfer pricing developments; • transfer pricing developments in the European Union; • transfer pricing developments in the United States; • transfer pricing developments in developing countries and emerging economies; • recent developments on transfer pricing documentation and country-by-country reporting; • recent developments on comparability analysis in transfer pricing; and • recent developments on the profit split method. The intense work of international organizations such as the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund, and other international organizations is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating an efficient dialogue and coordinated approach to transfer pricing in the future.
