Download or read book Hybrid Entities in Tax Treaty Law written by Sriram Govind and published by Linde Verlag GmbH. This book was released on 2020-09-03 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.

Download or read book Tax Treaty Case Law around the Globe 2022 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2023-11-29 with total page 480 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 provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. 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, Tax Treaty Case Law around the Globe 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

Download or read book Income tax conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1474 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 in 2016 around the world.

Download or read book Legislative History of United States Tax Conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1516 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Monthly Catalogue United States Public Documents written by and published by . This book was released on 1995 with total page 1100 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Congressional Record written by United States. Congress and published by . This book was released on 1971 with total page 1378 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Congressional Record is the official record of the proceedings and debates of the United States Congress. It is published daily when Congress is in session. The Congressional Record began publication in 1873. Debates for sessions prior to 1873 are recorded in The Debates and Proceedings in the Congress of the United States (1789-1824), the Register of Debates in Congress (1824-1837), and the Congressional Globe (1833-1873)

Download or read book The Department of State Bulletin written by and published by . This book was released on 1957 with total page 552 pages. Available in PDF, EPUB and Kindle. Book excerpt: The official monthly record of United States foreign policy.

Download or read book United States Treaties and Other International Agreements written by United States and published by . This book was released on 1973 with total page 1194 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Internal Revenue Bulletin written by United States. Bureau of Internal Revenue and published by . This book was released on 1958 with total page 2024 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book United States Congressional Serial Set Catalog written by and published by . This book was released on 1988 with total page 736 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Journal of the Senate of the United States of America written by United States. Congress. Senate and published by . This book was released on 1964 with total page 1116 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Treaties and Other International Acts Series written by United States and published by . This book was released on 1946 with total page 1152 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Trusts and Private Wealth Management written by Richard Nolan and published by Cambridge University Press. This book was released on 2023-01-31 with total page 343 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book illuminates the world of trust law, tackling contemporary issues such as the rise of Asian wealth and cryptoassets.

Download or read book OECD Arbitration in Tax Treaty Law written by Alicja Majdanska and published by Linde Verlag GmbH. This book was released on 2018-09-14 with total page 740 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.

Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.

Download or read book Doing Business In China written by Michael J. Moser and published by Juris Publishing, Inc.. This book was released on 2014-04-01 with total page 3686 pages. Available in PDF, EPUB and Kindle. Book excerpt: Doing Business in China provides over 3,000 pages of extensive and comprehensive analysis on Chinese business and commercial law and practice. This work is the most thorough reference and guide to all major areas of business law and investment in the People’s Republic of China, and offers a wide-ranging analysis and commentary on Chinese business laws. For over thirty years Doing Business in China has been one of the premier sources of practical information and analysis on issues affecting foreign investment in China. This multi - volume treatise captures the collective experiences and knowledge of prominent practitioners and business and legal experts with respect to the essential areas of PRC investment and commercial law. Designed for those who are either planning to invest in China or who already have an established presence, Doing Business in China provides a detailed examination of all relevant legislation and practice in China that affects business and investment. It also closely examines key issues and potential pitfalls involved in all areas of business and investment.