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Book Limitation on Benefits Clauses in Double Taxation Conventions

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.

Book Creating Fiscal Space for Poverty Reduction in Ecuador

Download or read book Creating Fiscal Space for Poverty Reduction in Ecuador written by and published by World Bank Publications. This book was released on 2005-01-01 with total page 283 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication reviews Ecuador's fiscal management and public expenditure policies in the context of its development and poverty reduction goals. Findings include that the country's impressive fiscal performance of 2003 is encouraging but fragile, as several structural bottlenecks could impede fiscal discipline and recovery. Reversing poverty trends is critical for the country's stability, and this can only be achieved with well-targeted, effective and efficient pro-poor programmes.

Book Finanzas municipales

Download or read book Finanzas municipales written by Catherine D. Farvacque-Vitkovic and published by World Bank Publications. This book was released on 2015-10-26 with total page 964 pages. Available in PDF, EPUB and Kindle. Book excerpt: Desde Detroit hasta Lahore, la mayoría de las ciudades del mundo enfrentan problemas financieros, y aun así se espera que lleven a cabo sus funciones cada vez más complejas. Finanzas municipales - Manual para los gobiernos locales toma partido. Se pone del lado de los alcaldes y de los responsables de los asuntos municipales. Son escasas las publicaciones sobre este tema dirigidas tan directa y pragmáticamente a las autoridades decisorias y al personal financiero a nivel local. El contenido y los mensajes principales procuran responder a las inquietudes y a las cuestiones que enfrentan diariamente las ciudades y los municipios en la administración de sus finanzas. Finanzas municipales - Manual para los gobiernos locales asume una posición. En ocho capítulos, en esta obra se pasa revista a las lecciones aprendidas sobre relaciones intergubernamentales; finanzas de las áreas metropolitanas; gestión financiera, de los ingresos, de los gastos y de los activos públicos; financiamiento externo, y medición del desempeño de las finanzas municipales. Abarca temas tales como la descentralización, la transparencia y la rendición de cuentas, y aborda temas menos explorados como la gestión de activos, la capacidad crediticia, la respuesta frente a crisis financieras y los mecanismos de presentación de informes a los diversos niveles de gobierno y a la ciudadanía. Finanzas municipales - Manual para los gobiernos locales hace un llamado a la acción. No solo aporta conocimientos de avanzada en muchas cuestiones técnicas, sino que también guía a los gobiernos locales en el laberinto de los instrumentos existentes. En particular, la autoevaluación de las finanzas municipales que se propone en el capítulo 8 debería ayudar a los municipios a evaluar su propia situación y a avanzar en la senda de las reformas.

Book Tax Systems

Download or read book Tax Systems written by Joel Slemrod and published by MIT Press. This book was released on 2013-12-13 with total page 235 pages. Available in PDF, EPUB and Kindle. Book excerpt: An approach to taxation that goes beyond an emphasis on tax rates to consider such aspects as administration, compliance, and remittance. Despite its theoretical elegance, the standard optimal tax model has significant limitations. In this book, Joel Slemrod and Christian Gillitzer argue that tax analysis must move beyond the emphasis on optimal tax rates and bases to consider such aspects of taxation as administration, compliance, and remittance. Slemrod and Gillitzer explore what they term a tax-systems approach, which takes tax evasion seriously; revisits the issue of remittance, or who writes the check to cover tax liability (employer or employee, retailer or consumer); incorporates administrative and compliance costs; recognizes a range of behavioral responses to tax rates; considers nonstandard instruments, including tax base breadth and enforcement effort; and acknowledges that tighter enforcement is sometimes a more socially desirable way to raise revenue than an increase in statutory tax rates. Policy makers, Slemrod and Gillitzer argue, would be well advised to recognize the interrelationship of tax rates, bases, enforcement, and administration, and acknowledge that tax policy is really tax-systems policy.

Book The Rational Spirit in Modern Continuum Mechanics

Download or read book The Rational Spirit in Modern Continuum Mechanics written by Chi-Sing Man and published by Springer. This book was released on 2004-07-06 with total page 918 pages. Available in PDF, EPUB and Kindle. Book excerpt: Through his voluminous and in?uential writings, editorial activities, organi- tional leadership, intellectual acumen, and strong sense of history, Clifford - brose Truesdell III (1919–2000) was the main architect for the renaissance of - tional continuum mechanics since the middle of the twentieth century. The present collection of 42 essays and research papers pays tribute to this man of mathematics, science, and natural philosophy as well as to his legacy. The ?rst ?ve essays by B. D. Coleman, E. Giusti, W. Noll, J. Serrin, and D. Speiser were texts of addresses given by their authors at the Meeting in memory of Clifford Truesdell, which was held in Pisa in November 2000. In these essays the reader will ?nd personal reminiscences of Clifford Truesdell the man and of some of his activities as scientist, author, editor, historian of exact sciences, and principal founding member of the Society for Natural Philosophy. The bulk of the collection comprises 37 research papers which bear witness to the Truesdellian legacy. These papers cover a wide range of topics; what ties them together is the rational spirit. Clifford Truesdell, in his address upon receipt of a Birkhoff Prize in 1978, put the essence of modern continuum mechanics succinctly as “conceptual analysis, analysis not in the sense of the technical term but in the root meaning: logical criticism, dissection, and creative scrutiny.

Book Pension and Annuity Income

Download or read book Pension and Annuity Income written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Comenzando su negocio en Illinois manual

Download or read book Comenzando su negocio en Illinois manual written by and published by . This book was released on 2008 with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book The North American Mosaic

    Book Details:
  • Author : Commission for Environmental Cooperation (Montréal, Québec). Secretariat
  • Publisher :
  • Release : 2001
  • ISBN :
  • Pages : 240 pages

Download or read book The North American Mosaic written by Commission for Environmental Cooperation (Montréal, Québec). Secretariat and published by . This book was released on 2001 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: The North American Mosaic has four overarching features. First, it is, to the extent feasible, based on comparable information on the status and trends of major indicators of the state of the environment in Canada,Mexico, and the United States. Second, the report confirms that these three countries together make up an incredibly complex, dynamic, and interconnected ecosystem in which humans play a dominant and decisive role. Third, the report raises important and sometimes disquieting questions concerning the sustainability of some current trends. Finally, the report is a reminder that our economic, social, and physical well-being are utterly dependent on the life-sustaining services provided by nature. This report emphasizes the importance of developing mutually compatible economic, social, and environmental goals and policies across the three-country region.

Book Transactional Adjustments in Transfer Pricing

Download or read book Transactional Adjustments in Transfer Pricing written by Aitor Navarro and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Global Investment Competitiveness Report 2017 2018

Download or read book Global Investment Competitiveness Report 2017 2018 written by World Bank Group and published by World Bank Publications. This book was released on 2017-10-25 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Global Investment Competitiveness report presents new insights and evidence on drivers of foreign direct investment (FDI) in developing countries, and FDI’s role in development. The report’s survey of 750 executives of multinational corporations finds that a business-friendly legal and regulatory environment is a key driver of investment decisions in developing countries, along with political stability, security, and macroeconomic conditions. The report’s topic-specific chapters explore the potential of FDI to create new growth opportunities for local firms, assess the power of tax holidays and other fiscal incentives to attract FDI, analyze characteristics of FDI originating in developing countries, and examine the experience of foreign investors in countries affected by conflict and fragility. Three key features of this Global Investment Competitiveness report distinguish it from other publications on FDI. First, its insights are based on a combination of first-hand perspectives of investors, extensive analysis of available data and evidence, and international good practices in investment policy design and implementation. Secondly, rather than exploring broad FDI trends, the report provides detailed and unique analysis of FDI depending on its motivation, sector, geographic origin and destination, and phase of investment. Thirdly, the report offers practical and actionable recommendations to policymakers in developing countries wishing to reform their business climates for increased investment competitiveness. As such, the report is meant to complement other knowledge products of the World Bank Group focused even more explicitly on country-level data, detailed reform diagnostics, and presentation of best practices. We are confident this report will bring value and fresh perspectives to a variety of audiences. To governments and policymakers, including investment promotion professionals, the report offers direct insights into the role of government policies and actions in investors’ decision-making. To foreign investors and site location consultants, the report provides information on FDI trends and drivers across sectors and geographies. For academic audiences, the new datasets on investment incentives and FDI motivations enables opportunities for additional research and analysis. Lastly, for development assistance providers and other stakeholders, the report highlights key approaches for maximizing FDI’s benefits for development.

Book Taxation and Migration

    Book Details:
  • Author : Reuven S. Avi-Yonah
  • Publisher : Kluwer Law International B.V.
  • Release : 2015-08-21
  • ISBN : 9041161449
  • Pages : 224 pages

Download or read book Taxation and Migration written by Reuven S. Avi-Yonah and published by Kluwer Law International B.V.. This book was released on 2015-08-21 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base decisions. Nowhere is this necessity more pressing than in the development of relevant tax rules that meet the basic requirements of efficiency and equity. Moreover, the ascent of the so-called emerging economies coupled with the stagnation of the richest economies of the world implies reform of the current competition-based international tax regime and the adoption of a more cooperative paradigm. This important and timely book, for the first time in such depth, explores such aspects of the problem as the following: - migration for tax reasons, especially corporate "inversions" (change in corporate residence for tax purposes); - tax consequences related to individuals who receive free or subsidized education in one country and profit from it in another; - taxing cross-border retirement income; and - migration-related aspects of tax preferential treatment of the elderly. With particular emphasis on the effects and opportunities created by the changing international tax regime - and with attention to the role of tax treaties and recent court cases - chapters by well known tax experts present evidence on the consequences of migration in all its facets and simulate the effects of several recently enacted and proposed changes in tax law in European countries, the United States, and other jurisdictions. The grounded propositions and recommendations offered in this deeply informed book will allow policymakers to draft tax-residence rules that minimize distortion and promote fairness. The book will also be of interest to tax law practitioners and other tax specialists, migration experts, and academics investigating one of the crucial political issues of our time.

Book Customs Modernization Handbook

Download or read book Customs Modernization Handbook written by Luc De Wulf and published by World Bank Publications. This book was released on 2005-01-03 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Trade integration contributes substantially to economic development and poverty alleviation. In recent years much progress was made to liberalize the trade regime, but customs procedures are often still complex, costly and non-transparent. This situation leads to misallocation of resources. 'Customs Modernization Handbook' provides an overview of the key elements of a successful customs modernization strategy and draws lessons from a number of successful customs reforms as well as from customs reform projects that have been undertaken by the World Bank. It describes a number of key import procedures, that have proved particularly troublesome for customs administrations and traders, and provides practical guidelines to enhance their efficiency. The Handbook also reviews the appropriate legal framework for customs operations as well as strategies to combat corruption.

Book Trafficking in Humans

Download or read book Trafficking in Humans written by Sally Cameron and published by . This book was released on 2008 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt: Brings social, economic and political elements to the policy discussion as well as strategic interventions regarding the fight against "trafficking" (the recruitment and transportation of human beings through deception and coercion for the purposes of exploitation). Trafficking, generally, occurs from poorer to more prosperous countries and regions; however, it is not necessarily the poorest regions or communities which are most vulnerable to trafficking, and so this volume seeks to identify the factors which explain where and why vulnerability increases.--Publisher description.

Book Tax Treaty Case Law around the Globe 2020

Download or read book Tax Treaty Case Law around the Globe 2020 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2021-08-04 with total page 278 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 in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. 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 2020” is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics

Book Entrepreneurship Policy  Theory and Practice

Download or read book Entrepreneurship Policy Theory and Practice written by Anders Lundstrom and published by Springer Science & Business Media. This book was released on 2005-09-21 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt: Entrepreneurship Policy: Theory and Practice is the first book to fully analyze the construction of entrepreneurship policy, a rapidly-evolving area of policy about which little is known. From a study and assessment of the practices of governments in thirteen countries in Europe, North America and the Asia-Pacific, this book fully describes the policy area and shares new tools and methods for better understanding and explaining the why and how of an entrepreneurship policy approach. Unlike other research in the field of entrepreneurship where implications from research findings are used to suggest what policy actions should be taken to increase the level of entrepreneurship in an economy, this study is based on what entrepreneurship policy actions are being taken. This is a unique book in the field which points to the way forward both for policymakers and for the research community in terms of thinking about entrepreneurship policy and the complex issues surrounding its development.

Book Current Approach to Heart Failure

Download or read book Current Approach to Heart Failure written by Maria Dorobanţu and published by Springer. This book was released on 2017-01-20 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is intended to be a link between guidelines and clinical practice, a complementary tool to help physicians to be well informed regarding the important field of heart failure. It will be a useful tool for professionals from all the fields of cardiology: non-invasive cardiology, interventional cardiology, electrophysiology and cardiovascular imaging. The topic of heart failure is continuously changing, with new important information being added constantly. The pathophysiology is better understood and there is a trend for a better characterization of special groups of population, such as oncologic patients with heart failure. The new imaging techniques have become valuable tools for the diagnosis of heart failure, while pharmacological and novel cell and gene treatments have evolved enormously. The challenge for the practitioners is making the right selection of treatment strategy that best fits a patient. This book presents detailed information on the indications, selection and mechanism of action of these treatments, whether they be mechanical circulatory devices or pharmacological treatments. The contemporary pharmacological and non-pharmacological management of heart failure has the main target of early prevention of disease progression and the avoidance of heart transplant. In the era of shortage of donors, prevention is the mainstay of the therapeutic strategy, and this is the main philosophy of our book.