Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 379 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Download or read book Yearbook of the United Nations Volume 41 1987 written by United Nations and published by Martinus Nijhoff Publishers. This book was released on 2023-11-27 with total page 1450 pages. Available in PDF, EPUB and Kindle. Book excerpt: Issued annually since 1946/47, the Yearbook is the principal reference work of the United Nations, providing a comprehensive, one-volume account of the Organization's work. It includes details of United Nations activities concerning trade, industrial development, natural resources, food, science and technology, social development, polulation, environment, human settlement, children and legal questions, along with information on the work of each specialized agency in the United Nations family.

Download or read book New International Yearbook written by and published by . This book was released on 1910 with total page 932 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Comparative Law Yearbook of International Business Volume 43 written by Christian Campbell and published by Kluwer Law International B.V.. This book was released on 2021-11-11 with total page 195 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.

Download or read book Yearbook of the United Nations Volume 39 1985 written by United Nations and published by Martinus Nijhoff Publishers. This book was released on 2023-08-28 with total page 1512 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Global Business Regulation written by John Braithwaite and published by Cambridge University Press. This book was released on 2000-02 with total page 724 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book confronts the question of how the regulation of business has shifted from national to global institutions. Based on interviews with 500 international leaders in business and government, this book examines the role played by global institutions such as the WTO, IMF and the World Bank, as well as various NGOs and significant individuals. The authors argue that effective and decent global regulation depends on the determination of individuals to engage with powerful agendas and decision-making bodies that would otherwise be dominated by concentrated economic interests.

Download or read book The Serials Directory written by and published by . This book was released on 1994 with total page 1784 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Yearbook of the United States Department of Agriculture written by and published by . This book was released on 1909 with total page 908 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Yearbook of Agriculture written by and published by . This book was released on 1909 with total page 946 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book 60TH CONGRESS 2d Session HOUSE OF REPRESENTATIVES DOCUMENT No 1560 YEARBOOK OF THE UNITED STATES DEPARTMENT OF AGRICULTURE 1908 written by and published by . This book was released on 1909 with total page 930 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Yearbook of the United Nations 45 1991 1992 written by United Nations. Dept. of Public Information and published by Martinus Nijhoff Publishers. This book was released on 1992-12-24 with total page 1162 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fully indexed, the 1991 edition of the "Yearbook" is the single most current, comprehensive and authoritative reference publication about the work of the United Nations, other international organizations and related bodies. The book is designed not just for use by diplomats, officials and scholars but also by other researchers, writers, journalists, teachers and students. The year 1991 was a remarkably eventful one for the United Nations and in the conduct of international relations. This volume of the "Yearbook" details the activities of the United Nations, its many organs, agencies and programmes, working together to rekindle a new form of multilateral cooperation for a better world. It records the diverse and globe-encompassing activities of the United Nations and its enduring efforts to deal with the world's pressing concerns, particularly matters of international peace and security, disarmament, human rights, the settlement of regional conflicts, economic and social development, the preservation of the environment, control of drugs and narcotic substance abuse, crime prevention, adequate shelter, youth and the ageing and humanitarian assistance for refugees as well as disaster relief. The "Yearbook of the United Nations" is now up-to-date. The Yearbooks for the years 1988, 1989 and 1990 will be published simultaneously.

Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

Download or read book Beneficial Ownership in International Tax Law written by Angelika Meindl-Ringler and published by Kluwer Law International B.V.. This book was released on 2016-06-07 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.

Download or read book The Oxford Handbook of International Tax Law written by Florian Haase and published by Oxford University Press. This book was released on 2023-09-22 with total page 1185 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.

Download or read book Charity Crossing Borders written by Sabine Heidenbauer and published by Kluwer Law International B.V.. This book was released on 2011-01-01 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: Throughout the European Union, national income tax systems support charitable activities by way of preferential treatment. However, a number of Member States operate relief regimes which appear to trigger the question of compatibility with Union law with respect to the fundamental freedoms. In this first study to examine charity and donor taxation regimes across a wide range of Member States, the author focuses on compatibility with EU non-discrimination law. She examines twenty national regimes, both comparatively and from the perspective of overarching EU law. The countries covered are Austria, Belgium, Bulgaria, Cyprus, Estonia, Finland, Germany, Hungary, Ireland, Italy, Latvia, Lithuania, Malta, The Netherlands, Poland, Portugal, Slovakia, Spain, Sweden, and the United Kingdom. Although charity and donor taxation falls within the competence of the Member States, they must nonetheless observe primary Union law and grant non-discriminatory treatment where a fact pattern falls within the ambit of the fundamental freedoms. In the course of defining this framework, the study addresses such issues as the following: types of relief schemes maintained for charities and donors; administrative requirements; international aspects (both inbound and outbound); privileged donations and capital gains treatment of in-kind donations; eligible donees; whether and to what extent charitable entities and donors can actually rely on the fundamental freedoms; specific applicability of each of the relevant fundamental freedoms; the issue of comparability; justifications for restrictive measures in Member State practice; and the issue of proportionality.

Download or read book Irregular Serials Annuals written by and published by . This book was released on 1986 with total page 1960 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Europa World Year Book 2003 written by Europa Publications and published by Taylor & Francis. This book was released on 2003 with total page 2470 pages. Available in PDF, EPUB and Kindle. Book excerpt: First published in 2003. Routledge is an imprint of Taylor & Francis, an informa company.