Download or read book Preventing Treaty Abuse written by Daniel Blum and published by Linde Verlag GmbH. This book was released on 2016-09-19 with total page 473 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse Peer Review Report on Treaty Shopping Inclusive Framework on BEPS Action 6 written by OECD and published by OECD Publishing. This book was released on 2019-02-14 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all Inclusive Framework members have committed to implement.This report reflects the outcome of the first peer review of the implementation ...
Download or read book OECD G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS Action 6 written by OECD and published by OECD Publishing. This book was released on 2024-03-20 with total page 325 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the sixth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse Fourth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS Action 6 written by OECD and published by OECD Publishing. This book was released on 2022-03-21 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fourth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS Action 6 written by OECD and published by OECD Publishing. This book was released on 2023-03-21 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Action 6 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 6.
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 OECD G20 Base Erosion and Profit Shifting Project Prevention of Treaty Abuse Second Peer Review Report on Treaty Shopping Inclusive Framework on BEPS Action 6 written by OECD and published by OECD Publishing. This book was released on 2020-03-24 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the second peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
Download or read book Model Tax Convention on Income and on Capital Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
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 OECD G20 Base Erosion and Profit Shifting Project Measuring and Monitoring BEPS Action 11 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 11.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy Action 1 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 1.
Download or read book The Political Economy of Public Finance written by Mustafa Çelen and published by Ijopec Publication. This book was released on 2017 with total page 238 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation International Cooperation and the 2030 Sustainable Development Agenda written by Irma Johanna Mosquera Valderrama and published by Springer Nature. This book was released on 2021-03-29 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: This open access volume addresses the link between international taxation, the 2030 Sustainable Development Agenda and the medium-term revenue strategy concept. It also analyses how countries and governments can reinforce this link in current and future initiatives in international taxation, including the base erosion profit shifting project initiated by the Organization for Economic Co-operation and Development with the political mandate of the G20. It discusses the 2030 Sustainable Development Agenda that are relevant for taxation and assesses the current work done by international organizations, regional tax organizations and countries to achieve these Sustainable Development Goals. The contributions to this volume provide an interdisciplinary mix of expertise in tax law, international political economy, global governance and international relations. Through these different perspectives, this volume provides an elaborate reference and evaluation framework for multilateral cooperation on tax and development to strengthen the revenue system of developed and developing countries. This topical volume is of interest to students and researchers of the social sciences, law and economics, as well as policy makers working on taxation.
Download or read book International Tax Aspects of Sovereign Wealth Investors written by Richard Snoeij and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 277 pages. Available in PDF, EPUB and Kindle. Book excerpt: An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.
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 678 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.
