Download or read book International Trade Subsidy Rules and Tax and Financial Export Incentives written by Paulo Penteado Neto and published by AuthorHouse. This book was released on 2012 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study researches interrelations between international trade subsidy rules and the use of tax and financial export incentives by developing countries. The author proclaims that developing countries should be allowed to adopt certain incentives without violating the WTO rules concerning subsidies. After a discussion about the right to development and the fair/just trade the author analyses the WTO concept of subsidy and its categories in light of the US-Foreign Sales Corporations (US-FSC) WTO case decision.

Download or read book International and EC Tax Aspects of Groups and Companies written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2008 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.

Download or read book Combating Tax Avoidance in the EU written by José Manuel Almudí Cid and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 880 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.

Download or read book Taxation and Development A Comparative Study written by Karen B. Brown and published by Springer. This book was released on 2017-01-16 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.

Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Download or read book Exchange of Information in the EU written by Marina Serrat Romaní and published by Edward Elgar Publishing. This book was released on 2024-04-12 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: This timely book provides a holistic analysis of the exchange of information procedures for tax purposes within the EU from an administrative law and tax law perspective. It explores how procedural and substantive taxpayers’ rights are affected by exchange of information processes, and rigorously examines the effectiveness of the current legal framework.

Download or read book Tax Treaty Case Law around the Globe 2017 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2018-02-20 with total page 417 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 2016. 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, the proposed book is a valuable reference tool for all tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics who are active in tax treaty case law.

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

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 The European Union and the accommodation of Basque difference in Spain written by Angela Bourne and published by Manchester University Press. This book was released on 2013-07-19 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: How does the European Union affect devolution and nationalist conflict in member states? Does the EU reduce the scope of regional self-government or enhance it? Does it promote conflict or cooperation among territorial entities? These are pressing questions in Spanish politics, where devolution has been an important tool for managing nationalist disputes, and for the Basque Country, where protracted and sometimes violent nationalist conflicts persist. Addressing these issues, this book explores prospects for an autonomous Basque role in EU politics; institutional arrangements for autonomous community participation in EU decision making; Basque government alliances with other regions and the EU's supranational bodies; EU incentives for collaboration among Basque and central state authorities; the impact of EU decisions on politically sensitive Basque competencies; and the incidence of EU issues in nationalist disputes. It presents a new theoretical framework for analysing the impact of the EU on regional power and will be of interest to students, researchers and general observers of Basque, Spanish and EU politics.

Download or read book EC Tax Review written by and published by . This book was released on 2002 with total page 728 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Tax Strategies for Corporate Acquisitions Dispositions Spin offs Joint Ventures and Other Strategic Alliances Financings Reorganizations and Restructurings written by and published by . This book was released on 2004 with total page 1332 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Open Budgets written by Sanjeev Khagram and published by Brookings Institution Press. This book was released on 2013 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explicates political economy factors that have brought about greater transparency and participation in budget settings across Asia, Africa, and Latin America. This title presents the strategies, policies, and institutions through which improvements can occur and produce change in policy and institutional outcomes.

Download or read book The Journal of International Taxation written by and published by . This book was released on 2001 with total page 514 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The mexican enigma written by Sergio Aguayo Quezada and published by Editorial Ink. This book was released on 2015-05-27 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The country´s future depends on what a conscious and organized society does, or fail to do". The mexican enigma is an informative analysis of the situation of political, social and economic crisis that Mexico is going through from the review of three key areas: the political elites —mainly figures like Enrique Peña Nieto, whom the author studies in a bibliographical manner as well as reviews his actions since he was governor of Estado de Mexico—; the de facto powers that have been developed in the country and its implications in Mexican political and social credibility; the last axis is organized society, which, from the perception of Aguayo, has always been excluded from Mexican politics. The author also discusses the state of political culture within society and the level of disapproval of this before the present form of the government of Mexico. The author makes a strong documentary research that reaches to an almost didactic text, bringing the reader to a real and well informed approach of what is happening in Mexico. The book, in digital format, allows interaction with documents, videos and photographs that complement the reading, while encouraging political reflection from its readers.

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 C digo do IRC e legisla o Complementar 2015 written by Vida Económica and published by Vida Economica Editorial. This book was released on 2015-04-14 with total page 195 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edição prática em formato de livro de bolso que inclui a Reforma do Código do IRC aprovado pelo Decreto- Lei n.º 442-B/88, de 30 de Novembro. Inclui ainda Legislação complementar: - Regime das Depreciações e Amortizações - Regime Complementar do Procedimento de Inspecção Tributária