Download or read book The Attribution of Profits to Permanent Establishments written by Raffaele Russo and published by IBFD. This book was released on 2005 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016

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 Catalog written by University of Texas. Library. Latin American Collection and published by . This book was released on 1969 with total page 700 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 Courts and Tax Treaty Law written by Guglielmo Maisto and published by IBFD. This book was released on 2007 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.

Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Download or read book Tax Institute Bookshelf written by Tax Institute of America and published by . This book was released on 1964 with total page 562 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Peruvian Economy written by Pan American Union. Division of Economic Research and published by . This book was released on 1950 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Host Bibliographic Record for Boundwith Item Barcode 30112044669122 and Others written by and published by . This book was released on 2013 with total page 2422 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book National Union Catalog written by and published by . This book was released on 1983 with total page 1032 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes entries for maps and atlases.

Download or read book General Catalogue of Printed Books written by British Museum. Department of Printed Books and published by . This book was released on 1969 with total page 1138 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Financialization of Latin American Real Estate Markets written by Alfonso Valenzuela Aguilera and published by Taylor & Francis. This book was released on 2022-07-13 with total page 217 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Financialization of Latin American Real Estate Markets: New Frontiers introduces the fundamental principles of urban economics, housing, and large-scale real estate development in Latin America and equips aspiring investors and developers with the foundations for success in a unique, dynamic region. Using case studies from the Americas, this textbook provides a framework for assessing the economic, technological, social, and political forces that shape urban space, helping readers understand the aims and risks of real estate investment. Chapters on economic theory, novel financial instruments, and the regulatory environment connect real-world practice to the latest scholarly conversations in urban planning, real estate finance and development, and regional studies. Informed by the author’s extensive experience as an academic and practitioner throughout the region, this distinctive resource sheds light on the relationship between financial capital and urban form, and places Latin American cities at the center of the urban economy debate. Features: Provides a thorough introduction to the mechanics of real estate markets, grounding spatial and economic theories with practical examples of the tools used to finance urban development in Latin America Centers around case studies from Mexico, Brazil, Chile, Panama, Argentina, and Colombia—some of the region’s most dynamic markets Presents financial instruments such as mortgage-backed securities, collateralized debt obligations, credit default swaps, and real estate investment trusts in a global context Examines State policies and programs for housing and infrastructure in Latin America, demonstrating regional patterns and new perspectives Covers real estate finance from housing to megaprojects, exploring recent trends in infrastructure, commercial centers, and tourism with an eye toward sustainable financing practices for the future Suitable for graduate and upper-level undergraduate students of real estate, urban planning, and Latin American studies, The Financialization of Latin American Real Estate Markets: New Frontiers also serves as essential reading for professionals in international real estate finance and development.

Download or read book The Evolution of the Mexican Tax System with Special Reference to Developments Since 1956 written by John Sidney Evans and published by . This book was released on 1971 with total page 594 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Subject Catalog written by Library of Congress and published by . This book was released on 1970 with total page 1012 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Taxation in Latin America written by and published by . This book was released on 1970 with total page 792 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Monographic Series written by Library of Congress and published by . This book was released on 1981 with total page 796 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book General Catalogue of Printed Books written by British Museum. Department of Printed Books and published by . This book was released on 1968 with total page 584 pages. Available in PDF, EPUB and Kindle. Book excerpt: