Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 471 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.

Download or read book Transfer Pricing Documentation and Country by country Reporting Action 13 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Download or read book OECD FAO Guidance for Responsible Agricultural Supply Chains written by OECD and published by OECD Publishing. This book was released on 2016-10-14 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt: OECD and FAO have developed this guidance to help enterprises observe standards of responsible business conduct and undertake due diligence along agricultural supply chains in order to ensure that their operations contribute to sustainable development.

Download or read book OECD Sovereign Borrowing Outlook 2021 written by OECD and published by OECD Publishing. This book was released on 2021-05-20 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition of the OECD Sovereign Borrowing Outlook reviews developments in response to the COVID-19 pandemic for government borrowing needs, funding conditions and funding strategies in the OECD area.

Download or read book Tax Challenges Arising from Digitalisation Interim Report 2018 written by Collectif and published by OECD. This book was released on 2018-05-29 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Download or read book Biodiversity Finance and the Economic and Business Case for Action written by OECD and published by OECD Publishing. This book was released on 2019-12-06 with total page 125 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report sets the economic and business case for urgent and ambitious action on biodiversity. It presents a preliminary assessment of current biodiversity-related finance flows, and discusses the key data and indicator gaps that need to be addressed to underpin effective monitoring of both the pressures on biodiversity and the actions (i.e. responses) being implemented. The report concludes with ten priority areas where G7 and other countries can prioritise their efforts.

Download or read book Measuring the Digital Transformation A Roadmap for the Future written by OECD and published by OECD Publishing. This book was released on 2019-03-11 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: Measuring the Digital Transformation: A Roadmap for the Future provides new insights into the state of the digital transformation by mapping indicators across a range of areas – from education and innovation, to trade and economic and social outcomes – against current digital policy issues, as presented in Going Digital: Shaping Policies, Improving Lives.

Download or read book International VAT GST Guidelines written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper set forth internationally agreed principles and standards for the value added tax (VAT) treatment of the most common types of international transactions, with a particular focus on trade in services and intangibles. Its aim is to minimise inconsistencies in the application of VAT in a cross-border context with a view to reducing uncertainty and risks of double taxation and unintended non-taxation in international trade. It also includes the recommended principles and mechanisms to address the challenges for the collection of VAT on crossborder sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project).

Download or read book Global Value Chains in a Postcrisis World written by Olivier Cattaneo and published by World Bank Publications. This book was released on 2010 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book looks to address the following questions in a post-crisis world: How have lead firms responded to the crisis? Have they changed their traditional supply chain strategy and relocated and/or outsourced part of their production? How will those changes affect developing countries? What should be the policy responses to these changes?

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Download or read book Global Value Chain Development Report 2021 written by Banque asiatique de développement and published by . This book was released on 2022-01-25 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A radical shift is underway in global value chains as they increasingly move beyond traditional manufacturing processes to services and other intangible assets. Digitization is a leading factor in this transformation, which is being accelerated by the coronavirus disease (COVID-19) pandemic. The Global Value Chain Development Report, the third of a biennial series, explores this shift beyond production. The report shows how the rise of services value chains offers a new path to development and how protectionism and geopolitical tensions, environmental risks, and pandemics are undermining the stability of global value chains and forcing their reorganization geographically. It is co-published by the WTO, the Asian Development Bank, the Research Institute for Global Value Chains at the University of International Business and Economics, the Institute of Developing Economies, and the China Development Research Foundation.

Download or read book World Development Report 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-19 with total page 545 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global value chains (GVCs) powered the surge of international trade after 1990 and now account for almost half of all trade. This shift enabled an unprecedented economic convergence: poor countries grew rapidly and began to catch up with richer countries. Since the 2008 global financial crisis, however, the growth of trade has been sluggish and the expansion of GVCs has stalled. Meanwhile, serious threats have emerged to the model of trade-led growth. New technologies could draw production closer to the consumer and reduce the demand for labor. And trade conflicts among large countries could lead to a retrenchment or a segmentation of GVCs. World Development Report 2020: Trading for Development in the Age of Global Value Chains examines whether there is still a path to development through GVCs and trade. It concludes that technological change is, at this stage, more a boon than a curse. GVCs can continue to boost growth, create better jobs, and reduce poverty provided that developing countries implement deeper reforms to promote GVC participation; industrial countries pursue open, predictable policies; and all countries revive multilateral cooperation.