Download or read book Taxmann s Permanent Establishment Emerging Trends Complete Guide for Resolution of Complexities Involved in the Concept of Permanent Establishment October 2020 Edition written by The Chamber of Tax Consultants and published by Taxmann Publications Private Limited. This book was released on 2020-11-17 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: The study of Permanent Establishment has emerged as intriguing and complex subject. This book serves as a complete guide for resolution of complexities involved in the concept of permanent establishment. The structure of the book is as follows: • This book opens up with ‘adaptation of Indian domestic tax laws’ to the ‘global trend’ • The advent of ‘Significant Economic Presence’ and its ramification on the changing concept on business connection has been deliberated in this book • Evolution of permanent establishment (‘PE’) in the e-world • Insights into Multilateral Conventions (‘MLI’) & OECDs position on the changing garb of PE • The book closes with the impact of changing philosophy of PE in the international tax space & in the domestic tax legislature. The contents of the book are as follows: • Introduction • Territorial nexus becomes aerial • Adaptation of Indian Domestic Laws • PE in digital economy • PE under Data Localisation Regime • Server as PE • Modification in Agency PE definition • Modification in Independent agent definition • Preparatory or auxiliary activities • Construction PE – Journey, Abuse and Remedy • Conclusion • Annexures 𝚘 Relevant Provisions of the Act 𝚘 OECD Model Convention (Relevant extract) 𝚘 PE Articles under various treaties 𝚘 Relevant Articles of Multilateral Conventions 𝚘 MLI Impact on PE Article of treaties extracted in Part III
Download or read book New Trends in the Definition of Permanent Establishment written by Guglielmo Maisto and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Download or read book Permanent Establishments A Planning Primer written by John Huston and published by Springer. This book was released on 1993-08-19 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a comprehensive review of the tax treaty concept of a `permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the `fixed place of business' and `dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.
Download or read book Taxmann s International Taxation A Compendium 5 200 Pages 200 Experts 137 Articles 4 Volumes 4th Edition written by The Chamber of Tax Consultants and published by Taxmann Publications Private Limited. This book was released on 2021-02-10 with total page 39 pages. Available in PDF, EPUB and Kindle. Book excerpt: CTC’s International Tax Compendium is a collection of incisive & in-depth articles on international taxation, which serves as a reference manual and indeed, a practice guide for its readers. The current edition of the compendium is more current, more incisive, covers a broader range of topics, and like its previous three editions, promises to be another very useful tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators ought to find this a useful reference point both for technical analysis as well as for understanding the right perspective in which to view some of the international tax developments of the recent past. This compendium will equip its readers with better knowledge and practical examples to be able to serve their clients better. The current edition of the compendium is a comprehensive four volumes set, containing approximately 5,200+ pages covering all major topics on the subject of International Taxation, such as: • Amendments made in the Income-tax Act, 1961 • Changes introduced in the OECD Model Tax Convention, 2017 • Updates introduced in the OECD Model Commentary in 2017 • Updates introduced in UN Model Tax Convention in 2017 • Global Focus on combating Tax Evasion • Initiation of various Anti Avoidance Measure and tightening of Anti Money Laundering Laws • Implementation of Multilateral Instruments pursuant to the publication of the BEPS Action Plan Reports in October, 2015. The Present Publications is the 4th Edition, covering 137 Articles authored by 200+ Experts. This Compendium is a balanced collection of articles by recognised experts in the field, by young as well as eminent professionals and also by experienced and knowledgeable Commissioners of Income-tax & Senior Ex- Revenue Officials. This book is divided into four volumes, and their contents (volume-wise) are listed below: • Volume 1 & 2 contains articles explaining the following: 𝚘 Theme/basic concepts of Double Tax Avoidance Agreements 𝚘 Various Articles of Model Tax Convention 𝚘 Specific provisions of the Domestic Law dealing with the Taxation of Non-Residents and Cross-Border Transactions • Volume 3 contains industry specific articles such as: 𝚘 Taxation of Telecom Sector 𝚘 Broadcasting & Telecasting industries 𝚘 Electronic Commerce 𝚘 Foreign Banks, Offshore Funds, FII’s etc. • Volume 4 contains articles on the following: 𝚘 FEMA and other Domestic Laws such as Prevention of Money Laundering Act, Foreign Contribution Regulation Act, Black Money Act, Benami Law 𝚘 Various Anti-Avoidance Measures & other specialised articles
Download or read book Tax Administration 2021 Comparative Information on OECD and other Advanced and Emerging Economies written by OECD and published by OECD Publishing. This book was released on 2021-09-15 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Download or read book Mapping Crime written by Keith D. Harries and published by . This book was released on 1995 with total page 220 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Capital in the Twenty First Century written by Thomas Piketty and published by Harvard University Press. This book was released on 2017-08-14 with total page 817 pages. Available in PDF, EPUB and Kindle. Book excerpt: What are the grand dynamics that drive the accumulation and distribution of capital? Questions about the long-term evolution of inequality, the concentration of wealth, and the prospects for economic growth lie at the heart of political economy. But satisfactory answers have been hard to find for lack of adequate data and clear guiding theories. In this work the author analyzes a unique collection of data from twenty countries, ranging as far back as the eighteenth century, to uncover key economic and social patterns. His findings transform debate and set the agenda for the next generation of thought about wealth and inequality. He shows that modern economic growth and the diffusion of knowledge have allowed us to avoid inequalities on the apocalyptic scale predicted by Karl Marx. But we have not modified the deep structures of capital and inequality as much as we thought in the optimistic decades following World War II. The main driver of inequality--the tendency of returns on capital to exceed the rate of economic growth--today threatens to generate extreme inequalities that stir discontent and undermine democratic values if political action is not taken. But economic trends are not acts of God. Political action has curbed dangerous inequalities in the past, the author says, and may do so again. This original work reorients our understanding of economic history and confronts us with sobering lessons for today.
Download or read book Principles of Management written by David S. Bright and published by . This book was released on 2023-05-16 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Black & white print. Principles of Management is designed to meet the scope and sequence requirements of the introductory course on management. This is a traditional approach to management using the leading, planning, organizing, and controlling approach. Management is a broad business discipline, and the Principles of Management course covers many management areas such as human resource management and strategic management, as well as behavioral areas such as motivation. No one individual can be an expert in all areas of management, so an additional benefit of this text is that specialists in a variety of areas have authored individual chapters.
Download or read book International VAT GST Guidelines written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper set forth internationally agreed principles and standards for the value added tax (VAT) treatment of the most common types of international transactions, with a particular focus on trade in services and intangibles. Its aim is to minimise inconsistencies in the application of VAT in a cross-border context with a view to reducing uncertainty and risks of double taxation and unintended non-taxation in international trade. It also includes the recommended principles and mechanisms to address the challenges for the collection of VAT on crossborder sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project).
Download or read book Yes Africa Can written by Punam Chuhan-Pole and published by World Bank Publications. This book was released on 2011-06-24 with total page 497 pages. Available in PDF, EPUB and Kindle. Book excerpt: Takes an in-depth look at twenty-six economic and social development successes in Sub-Saharan African countries, and addresses how these countries have overcome major developmental challenges.
Download or read book The Transfer Pricing Law Review written by Steve Edge and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Mergers Acquisitions and Corporate Restructurings written by Patrick A. Gaughan and published by John Wiley & Sons. This book was released on 2017-11-27 with total page 819 pages. Available in PDF, EPUB and Kindle. Book excerpt: The essential M&A primer, updated with the latest research and statistics Mergers, Acquisitions, and Corporate Restructurings provides a comprehensive look at the field's growth and development, and places M&As in realistic context amidst changing trends, legislation, and global perspectives. All-inclusive coverage merges expert discussion with extensive graphs, research, and case studies to show how M&As can be used successfully, how each form works, and how they are governed by the laws of major countries. Strategies and motives are carefully analyzed alongside legalities each step of the way, and specific techniques are dissected to provide deep insight into real-world operations. This new seventh edition has been revised to improve clarity and approachability, and features the latest research and data to provide the most accurate assessment of the current M&A landscape. Ancillary materials include PowerPoint slides, a sample syllabus, and a test bank to facilitate training and streamline comprehension. As the global economy slows, merger and acquisition activity is expected to increase. This book provides an M&A primer for business executives and financial managers seeking a deeper understanding of how corporate restructuring can work for their companies. Understand the many forms of M&As, and the laws that govern them Learn the offensive and defensive techniques used during hostile acquisitions Delve into the strategies and motives that inspire M&As Access the latest data, research, and case studies on private equity, ethics, corporate governance, and more From large megadeals to various forms of downsizing, a full range of restructuring practices are currently being used to revitalize and supercharge companies around the world. Mergers, Acquisitions, and Corporate Restructurings is an essential resource for executives needing to quickly get up to date to plan their own company's next moves.
Download or read book When Prisoners Return to the Community written by Joan Petersilia and published by . This book was released on 2000 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Successful Public Policy written by Joannah Luetjens and published by ANU Press. This book was released on 2019-04-30 with total page 551 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Australia and New Zealand, many public projects, programs and services perform well. But these cases are consistently underexposed and understudied. We cannot properly ‘see’—let alone recognise and explain—variations in government performance when media, political and academic discourses are saturated with accounts of their shortcomings and failures, but are next to silent on their achievements. Successful Public Policy: Lessons from Australia and New Zealand helps to turn that tide. It aims to reset the agenda for teaching, research and dialogue on public policy performance. This is done through a series of close-up, in-depth and carefully chosen case study accounts of the genesis and evolution of stand-out public policy achievements, across a range of sectors within Australia and New Zealand. Through these accounts, written by experts from both countries, we engage with the conceptual, methodological and theoretical challenges that have plagued extant research seeking to evaluate, explain and design successful public policy. Studies of public policy successes are rare—not just in Australia and New Zealand, but the world over. This book is embedded in a broader project exploring policy successes globally; its companion volume, Great Policy Successes (edited by Paul ‘t Hart and Mallory Compton), is published by Oxford University Press (2019).
Download or read book Citizenship in a Connected Canada written by Elizabeth Dubois and published by University of Ottawa Press. This book was released on 2020-11-10 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: No detailed description available for "Citizenship in a Connected Canada".
Download or read book Combating Fiscal Fraud and Empowering Regulators written by Brigitte Unger and published by Oxford University Press. This book was released on 2021 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is an open access title available under the terms of a CC BY-NC-ND 4.0 International licence. It is free to read at Oxford Scholarship Online and offered as a free PDF download from OUP and selected open access locations. Combating Fiscal Fraud and Empowering Regulators analyzes the impact of new international tax regulations on the scope and scale of tax evasion, tax avoidance, and money laundering. These are analyzed through an ecosystem framework in which, similar to a natural ecosystem, new tax regulations appear as heavy shocks to the tax ecosystem, to which the 'species' such as countries, corporations, and tax experts will react by looking for new loopholes and niches of survival. By analyzing the impact of tax reforms from different perspectives--a legal, political science, accounting, and economic one--one may derive an assessment of the reforms and policy recommendations for an improved international tax system. The ultimate goal is to combat fiscal fraud and empower regulators, in that line, this volume is intended for a broad audience that seeks to know more about the latest state of the art in the realm of taxation from a multidisciplinary perspective. The money involved amounts to billions in unpaid taxes that could be better used for stopping hunger, guaranteeing education, and safeguarding biodiversity, hence making this world a better one. Regulators can see this book as a guiding light of what has happened in the past forty years, and how the world has and will continue to change as a result of it. Combating Fiscal Fraud and Empowering Regulators is also a warning about new emerging tax loopholes, such as freeports or golden passports and visas, where residency can be bought in tax havens, even within the European Union. The main message is that inequality can and has to be reduced substantially and that this can be achieved through a well-working international tax system that eliminates secrecy, opaqueness, and tax havens.
