Download or read book Taxation of Investment Funds in the European Union written by Tomi Viitala and published by IBFD. This book was released on 2005 with total page 427 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Download or read book Investment Fund Taxation written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2017-04-24 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.
Download or read book Tax Treatment of Investment Funds and Their Investors Within the European Union written by Tomi Viitala and published by . This book was released on 2004 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 378 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 The Principle of Equality in European Taxation written by and published by . This book was released on 1999 with total page 279 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Real Estate Investment Trusts In Europe written by Wolfgang Speckhahn and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that investments in real estate provide relatively stable yields compared with stock market volatility, so it is not surprising that, with globalisation, investors have pursued such opportunities across borders, especially where foreign countries offer beneficial tax regimes. Nor it is surprising that states should fear erosion of their tax base in the presence of such investments. This groundbreaking book – the first in-depth comparative analysis of taxation of real estate investment trusts (REITs) in different European Union (EU) Member States – investigates the impact of EU law on direct taxation in the case of REITs, and whether EU policies in this area have led national legislators to adjust their REIT regimes. Presenting detailed case studies of three EU Member States – France (a well-established REIT regime), Bulgaria (a new accession state) and Spain (a recent REIT regime) – this book explores the idea of a harmonised EU REIT, and whether harmonisation among national REIT regimes may be possible. Among the issues and topics arising in the course of the presentation are the following: – ‘goodness of fit’ and adaptational soft pressure; – relevant case law from the European Court of Justice, including both tax and company law; – ‘REIT shopping’; – noncompliance of REIT regimes with EU law; and – criteria for the ‘misfit’ analysis of REIT regimes and potential infringements of EU law. The analysis ultimately documents conditions and circumstances for the creation of a harmonised ‘Euro-REIT’ by assessing the level of change on the area of direct taxation within the Member States which would be needed for such a creation to become reality, identifying common themes across different legal systems that could assist the harmonisation of laws. Throughout, a holistic view is taken, linking tax and company law with considerations of sovereignty, policy and culture. In its structured framework comparing REIT regimes, this incomparable study takes a giant step towards overcoming resistance to a common REIT taxation regime in the EU. As the first comparative study of REIT regimes to identify an emerging common understanding informed by European jurisprudence and Europeanisation policy and theory, it is sure to be welcomed by practitioners, academics and policymakers in European law and international taxation as well as European studies.
Download or read book European Union Direct Taxes written by Salvador Trinxet Llorca and published by Asset Protection Publishing. This book was released on 2010 with total page 160 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Common Tax Base for Multinational Enterprises in the European Union written by Carsten Wendt and published by Springer Science & Business Media. This book was released on 2009-04-16 with total page 231 pages. Available in PDF, EPUB and Kindle. Book excerpt: Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.
Download or read book Taxation of Foreign Direct Investment An Introduction written by Alex Easson and published by Springer. This book was released on 1999-08-24 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book describes the many different ways in which national tax rules and international tax principles affect foreign direct investment decisions, and examines their impact on the establishment and operation of foreign-invested projects. It focuses on tax provisions in both host and home countries, and looks at the role of tax treaties, the methods of relieving double taxation and of countering tax avoidance.
Download or read book Tax Incentives for Foreign Direct Investment written by A. J. Easson and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: Each national report addresses, among other things, the following issues: - the sources of law and general principle of the law of evidence - the means of evidence - the role of the judge and the parties in the evidence procedure - the evaluation of evidence - the production of evidence - the registration of produced evidence - the possibilities to admit new evidence or to renew evidence in appeal proceedings.
Download or read book European Union Corporate Tax Law written by Christiana H. J. I. Panayi and published by Cambridge University Press. This book was released on 2021-06-17 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies, and permanent establishments. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.
Download or read book Business Taxation in the European Union written by Gloria Teixeira and published by Wiley. This book was released on 1999-04-22 with total page 570 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written on a country-by-country basis, this book offers an analysis of the tax consequences and practical necessities of foreign investment in European Union countries: setting up new companies, merging with local companies, establishing branches/subsidiaries/permanent establishments, purchasing shares in domestic companies and equity versus debt finance. Discusses the corporate tax system of each country, the rules on the taxation of the parent-subsidiary relationship and the impact of double tax treaties.
Download or read book European Union Corporate Tax Law written by Christiana HJI Panayi and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted"--
Download or read book EU Freedoms Non EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Download or read book Switzerland Business Investment Handbook written by Christian H. Kälin and published by orell füssli. This book was released on 2006 with total page 774 pages. Available in PDF, EPUB and Kindle. Book excerpt: With contributions from well-known specialists in law, taxation, banking and asset management, and real estate, Switzerland Investment Handbook is the first detailed publication in English and comprehensive reference on the subject of doing business and investing in Switzerland. The book offers an all-inclusive look at the fundamental issues and practical aspects important to foreign individuals and firms doing business or investing in Switzerland.
Download or read book Corporate Tax Policy and Incorporation in the EU written by Ruud A. de Mooij and published by . This book was released on 2008 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Treatment and Taxation of Foreign Investment Under International Law written by Fiona Beveridge and published by Manchester University Press. This book was released on 2000 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is an examination of key issues concerning the treatment of foreign investment and the taxation of investors. It looks at some of the challenges which globalization has thrown up for the international community from a legal perspective and sets recent developments alongside more traditional approaches. Particular attention is paid to the needs and aspirations of developing countries and the implications for them of the current free trade orthodoxy. After outlining the established framework of laws concerning investment protection and taxation, the author looks at experiences in the European Union and the North Atlantic Free Trade Agreement and at a range of recent disputes and legal developments to assess whether international legal regimes are responding adequately to meet the needs of states and investors alike. Recent OECD initiatives on taxation and the aborted Multilateral Agreement on Investment negotiations are examined in conjunction with the relevant provisions of the World Trade Organization Agreements.
