Download or read book OECD Fiscal Federalism Studies Institutions of Intergovernmental Fiscal Relations Challenges Ahead written by Korea Institute of Public Finance and published by OECD Publishing. This book was released on 2015-11-18 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book takes an interdisciplinary look at how the institutions of intergovernmental fiscal relations are shaped, drawing on work by both academics and practitioners in the field.

Download or read book Time and Tax Issues in International EU and Constitutional Law written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 434 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.

Download or read book Imposing Standards written by Martin Hearson and published by Cornell University Press. This book was released on 2021-06-15 with total page 162 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Imposing Standards, Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits on the ability of developing countries to tax businesses, denying the Global South access to much-needed revenue. The international rules that allow tax avoidance by multinational corporations have dominated political debate about international tax in the United States and Europe, especially since the global financial crisis of 2007–2008. Hearson asks how developing countries willingly gave up their right to tax foreign companies, charting their assimilation into an OECD-led regime from the days of early independence to the present day. Based on interviews with treaty negotiators, policymakers and lobbyists, as well as observation at intergovernmental meetings, archival research, and fieldwork in Africa and Asia, Imposing Standards shows that capacity constraints and imperfect negotiation strategies in developing countries were exploited by capital-exporting states, shielding multinationals from taxation and depriving nations in the Global South of revenue they both need and deserve. Thanks to generous funding from the Gates Foundation, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.

Download or read book Intergovernmental Relations in Divided Societies written by Yonatan T. Fessha and published by Springer Nature. This book was released on 2022-01-10 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edited volume examines the form and operation of intergovernmental relations in divided societies. Using eight country case studies, it explores the interplay between politicised ethno-cultural diversity and intergovernmental relations (IGR) in countries where the distinctive identity of at least one subnational unit is acknowledged in a form of territorial autonomy. The book examines whether and how the distinctive identity of particular subnational units and the attending competing constitutional visions shape the dynamics of IGR. The goal here is not simply to determine whether intergovernmental interactions in such societies are less cordial and more conflictual than in other societies. Such interaction in any society could be strained as a result of disagreement over specific policy objectives. The question is whether the distinctive identity of particular subnational units and the attending competing constitutional visions themselves have been a primary source of intergovernmental tension. The book also examines the impact of identity politics on institutions and instruments of IGR, determining whether the ethno-cultural divide and the tension it creates have the tendency to affect the type of institutions and instruments employed in IGR. It is also about the relevance and effectiveness of institutions and instruments of IGR in acknowledging and accommodating the distinctive identities and specific demands of subnational units, thereby contributing to the peaceful management of divided societies.

Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 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) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.

Download or read book The Politics of Intergovernmental Relations written by David C. Nice and published by Wadsworth Publishing Company. This book was released on 1995 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: EXCERPT ONLY : Selected readings Chapters 1, 2, 4, 5, 6 and 8.

Download or read book The Public International Law of Taxation written by Asif H. Qureshi and published by Kluwer Law International B.V.. This book was released on 2019-05-22 with total page 912 pages. Available in PDF, EPUB and Kindle. Book excerpt: The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.

Download or read book Intergovernmental Relations in Transition written by Carl W. Stenberg and published by Routledge. This book was released on 2018-04-09 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: The field of intergovernmental relations has changed substantially over the past five decades. It maintains a critical and evolving role in the US federal system as well as in public policy and administration. Building upon the legacy of Deil S.Wright’s scholarship, this collection of essays by distinguished scholars, emerging thought leaders, and experienced practitioners chronicles and analyzes some of the tensions and pressures that have contributed to the current state of intergovernmental relations and management. Although rarely commanding media attention by name, intergovernmental relations is being elevated in the public discourse through policy issues dominating the headlines. Many of these intergovernmental issues are addressed in this book, including health insurance exchanges under the now-threatened Affordable Care Act, and the roles of the federal, state, and local governments in food safety, energy, and climate change.Contributors interpret and assess the impacts of these and other issues on the future directions of intergovernmental relations and management. This book will serve as an ideal text for courses on intergovernmental relations and federalism, and will be of interest to government practitioners and civic and nonprofit organization leaders involved in public policy and management.

Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Download or read book Cross Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.

Download or read book Intergovernmental Fiscal Relations written by Linda Goncalves Veiga and published by . This book was released on 2014-09-30 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Hybrid Financial Instruments Double Non Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 668 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

Download or read book Fiscal Regimes for Extractive Industries Design and Implementation written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2012-08-16 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Download or read book The EU and Third Countries written by Michael Lang and published by Kluwer Law International. This book was released on 2007 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis by tax scholars on the relations between European law and third countries in the field of direct taxation. It includes national reports from over 30 EU Member States and third countries, which were presented at a conference held at the Vienna University of Economics and Business Administration on 13-15 October 2006. Among the areas addressed by this work are the following: The direct impact of article 56 EC Treaty (right of establishment) in the relations with third states; The indirect impact of the fundamental freedoms in the relations with third states; Fundamental freedoms in relation to EEA States under the EEA Agreement; Agreements between Switzerland and the European Union; The relations with other third states in the field of direct taxes; The impact of secondary EC law on the relations with third states; Article 307 EC Treaty (free movement of capital); and The treaty-making power of the European Union in the relations with third states.

Download or read book Building Tax Culture Compliance and Citizenship A Global Source Book on Taxpayer Education Second Edition written by OECD and published by OECD Publishing. This book was released on 2021-11-24 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt: Widespread voluntary tax compliance plays a significant role in countries’ efforts to raise the revenues necessary to achieve Sustainable Development Goals. As part of this process, governments are increasingly reaching out to taxpayers – current and future – to teach, communicate and assist them in order to foster a “culture of compliance” based on rights and responsibilities, in which citizens see paying taxes as an integral aspect of their relationship with their government.

Download or read book Bridging the Tax Gap written by Max Sawicky and published by . This book was released on 2005 with total page 160 pages. Available in PDF, EPUB and Kindle. Book excerpt: Offering thorough understanding of the crisis facing federal tax administration and suggesting practical approach to solving issues that have arisen.