Download or read book The Interpretation and Application of the Preamble and Article 6 1 of the OECD Multilateral Instrument in the Context of North American Tax Treaty Networks written by J.A. Becerra and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the influence, if any, of the Preamble and article 6(1) of the OECD Multilateral Instrument (MLI), with particular focus on the extent to which they will modify the interpretation and application of the existing tax treaties in Canada, Costa Rica and Mexico.
Download or read book A Practical Approach to Determine the Influence of the OECD Multilateral Instrument on North American Tax Treaty Networks written by J.A. Becerra and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the practical influence of the OECD Multilateral Instrument (MLI), with particular focus on the extent to which it will modify, if at all, and affect the interpretation and application of the existing tax treaties of selected North American countries, i.e. Canada, Mexico and the United States.
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 MULTILATERAL INSTRUMENT FOR UPDATING THE TAX TREATY NETWORK written by NATHALIE. BRAVO and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treaty Abuse and the Pricipal Purpose Test Part 1 written by D.G. Duff and published by . This book was released on 2018 with total page 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) came into force on 1 July 2018, and has been signed by more than 80 jurisdictions, including Canada. This MLI has been described as "a historical turning point in the area of international taxation"; it introduces a third layer of rules for the taxation of cross-border transactions, in addition to domestic tax law and bilateral tax treaties. Of the many provisions of the MLI, the most important are the preamble text in article 6(1) and the general anti-avoidance provision - the so-called principal purpose test (PPT) - in article 7(1). Both of these provisions have been adopted by all signatories to the MLI in order to satisfy the OECD's minimum standard on tax treaty abuse under BEPS Action 6. This two-part article considers the structure and potential application of the PPT in the context of pre-BEPS responses to perceived tax treaty abuses, the OECD's work on BEPS Action 6, and other provisions of the MLI, including the preamble text in article 6(1). This first part of the article reviews pre-BEPS responses to perceived tax treaty abuses, providing necessary background and context for understanding BEPS Action 6, the MLI, and the PPT. The second part examines the PPT in light of this background and in the context of BEPS Action 6 and other provisions of the MLI, considering the structure of this provision and the kinds of transactions or arrangements to which it might apply.
Download or read book Tax Treaty Interpretation written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2001-12-19 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.
Download or read book An Explanatory Guide to the Nagoya Protocol on Access and Benefit sharing written by Thomas Greiber and published by IUCN. This book was released on 2012 with total page 395 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Aarhus Convention written by and published by . This book was released on 2014 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: United Nations publication sales no. E.13.II.E.3"--Page 4 of cover.
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 Judicial Interpretation of Tax Treaties written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2016-10-28 with total page 699 pages. Available in PDF, EPUB and Kindle. Book excerpt: Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.
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 The Road to Results written by Linda G. Morra-Imas and published by World Bank Publications. This book was released on 2009 with total page 611 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'The Road to Results: Designing and Conducting Effective Development Evaluations' presents concepts and procedures for evaluation in a development context. It provides procedures and examples on how to set up a monitoring and evaluation system, how to conduct participatory evaluations and do social mapping, and how to construct a "rigorous" quasi-experimental design to answer an impact question. The text begins with the context of development evaluation and how it arrived where it is today. It then discusses current issues driving development evaluation, such as the Millennium Development Goals and the move from simple project evaluations to the broader understandings of complex evaluations. The topics of implementing 'Results-based Measurement and Evaluation' and constructing a 'Theory of Change' are emphasized throughout the text. Next, the authors take the reader down 'the road to results, ' presenting procedures for evaluating projects, programs, and policies by using a 'Design Matrix' to help map the process. This road includes: determining the overall approach, formulating questions, selecting designs, developing data collection instruments, choosing a sampling strategy, and planning data analysis for qualitative, quantitative, and mixed method evaluations. The book also includes discussions on conducting complex evaluations, how to manage evaluations, how to present results, and ethical behavior--including principles, standards, and guidelines. The final chapter discusses the future of development evaluation. This comprehensive text is an essential tool for those involved in development evaluation.
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 Realizing the Right to Development written by United Nations. Office of the High Commissioner for Human Rights and published by . This book was released on 2013 with total page 584 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is devoted to the 25th anniversary of the United Nations Declaration on the Right to Development. It contains a collection of analytical studies of various aspects of the right to development, which include the rule of law and good governance, aid, trade, debt, technology transfer, intellectual property, access to medicines and climate change in the context of an enabling environment at the local, regional and international levels. It also explores the issues of poverty, women and indigenous peoples within the theme of social justice and equity. The book considers the strides that have been made over the years in measuring progress in implementing the right to development and possible ways forward to make the right to development a reality for all in an increasingly fragile, interdependent and ever-changing world.
Download or read book Policy Framework for Investment written by OECD and published by OECD Publishing. This book was released on 2006-05-11 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Drawing on good practices from OECD and non-OECD countries, the Framework proposes a set of questions for governments to consider in ten policy fields as critically important for the quality of a country’s environment for investment.
