Author: Thomas Ecker
Publisher: IBFD
ISBN: 908722172X
Category : Double taxation
Languages : en
Pages : 493
Book Description
Given the increasing problem of double taxation concerning value added tax (VAT)/goods and services tax (GST) and the resulting constraints to international trade, it is time for the international community to take action. This book analyses the phenomenon of VAT/GST double taxation and possible remedies. VAT/GST treaties would be one of them. But how should one design a VAT/GST treaty? To what extent do existing income tax treaties already apply to VAT/GST? Can income tax treaties simply be extended to VAT/GST or is there a need for a separate, independent VAT/GST treaty? Can the concepts, functioning, and structure of income tax treaties be used for VAT/GST purposes? What are possible alternatives? What should the scope of a VAT/GST treaty be? How can taxing rights be allocated between the parties to a treaty?
A VAT/GST Model Convention
Author: Thomas Ecker
Publisher: IBFD
ISBN: 908722172X
Category : Double taxation
Languages : en
Pages : 493
Book Description
Given the increasing problem of double taxation concerning value added tax (VAT)/goods and services tax (GST) and the resulting constraints to international trade, it is time for the international community to take action. This book analyses the phenomenon of VAT/GST double taxation and possible remedies. VAT/GST treaties would be one of them. But how should one design a VAT/GST treaty? To what extent do existing income tax treaties already apply to VAT/GST? Can income tax treaties simply be extended to VAT/GST or is there a need for a separate, independent VAT/GST treaty? Can the concepts, functioning, and structure of income tax treaties be used for VAT/GST purposes? What are possible alternatives? What should the scope of a VAT/GST treaty be? How can taxing rights be allocated between the parties to a treaty?
Publisher: IBFD
ISBN: 908722172X
Category : Double taxation
Languages : en
Pages : 493
Book Description
Given the increasing problem of double taxation concerning value added tax (VAT)/goods and services tax (GST) and the resulting constraints to international trade, it is time for the international community to take action. This book analyses the phenomenon of VAT/GST double taxation and possible remedies. VAT/GST treaties would be one of them. But how should one design a VAT/GST treaty? To what extent do existing income tax treaties already apply to VAT/GST? Can income tax treaties simply be extended to VAT/GST or is there a need for a separate, independent VAT/GST treaty? Can the concepts, functioning, and structure of income tax treaties be used for VAT/GST purposes? What are possible alternatives? What should the scope of a VAT/GST treaty be? How can taxing rights be allocated between the parties to a treaty?
International VAT/GST Guidelines
Author: OECD
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264272040
Category : Intangible property
Languages : en
Pages : 0
Book Description
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).
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264272040
Category : Intangible property
Languages : en
Pages : 0
Book Description
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).
Model Tax Convention on Income and on Capital: Condensed Version 2008
Author: OECD
Publisher: OECD Publishing
ISBN: 9264048197
Category :
Languages : en
Pages : 415
Book Description
This Condensed Version of the OECD Model Tax Convention contains the articles and commentaries of the Model Tax Convention as it read on 17 July 2008.
Publisher: OECD Publishing
ISBN: 9264048197
Category :
Languages : en
Pages : 415
Book Description
This Condensed Version of the OECD Model Tax Convention contains the articles and commentaries of the Model Tax Convention as it read on 17 July 2008.
Justice, Equality and Tax Law
Author: Nevia Čičin-Šain
Publisher: Linde Verlag GmbH
ISBN: 3709412587
Category : Law
Languages : en
Pages : 541
Book Description
An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.
Publisher: Linde Verlag GmbH
ISBN: 3709412587
Category : Law
Languages : en
Pages : 541
Book Description
An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.
Model Tax Convention on Income and on Capital: Condensed Version 2017
Author: OECD
Publisher: OECD Publishing
ISBN: 9264287957
Category :
Languages : en
Pages : 658
Book Description
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...
Publisher: OECD Publishing
ISBN: 9264287957
Category :
Languages : en
Pages : 658
Book Description
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...
Value Added Tax and Direct Taxation
Author: Michael Lang
Publisher: IBFD
ISBN: 908722060X
Category : Direct taxation
Languages : en
Pages : 1341
Book Description
This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.
Publisher: IBFD
ISBN: 908722060X
Category : Direct taxation
Languages : en
Pages : 1341
Book Description
This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.
Taxing Global Digital Commerce
Author: Arthur Cockfield
Publisher: Kluwer Law International B.V.
ISBN: 9041167110
Category : Law
Languages : en
Pages : 529
Book Description
Digital commerce – the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services – has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well. This latest edition of the preeminent text on the taxation of digital transactions revises, updates and expands the book’s coverage. It includes a detailed and up-to-date analysis of income tax and VAT developments regarding digital commerce under the OECD and G20 Base Erosion and Profit Shifting (BEPS) reforms. It explores the implications of digital commerce for US state sales and use tax regimes resulting from the 2018 US Supreme Court decision in Wayfair. It discusses cross-border tax in the United States while continuing to focus on tax developments throughout the world. Analysing the practical tax consequences of digital commerce from a multijurisdictional perspective, and using examples to illustrate the application of different taxes to digital commerce transactions, the book offers in-depth treatment of such topics as the following: how tax rules governing cross-border digital commerce are increasingly applied to all cross-border activities; how tax rules and institutional processes have evolved to confront challenges posed by digital commerce; how an emerging ‘tax war’ is developing whereby different countries are unilaterally imposing new tax rules on cross-border digital commerce; how technology enhances tax and cross-border tax information exchanges; how technology reduces both compliance and enforcement costs; cross-border consumption tax issues raised by cloud computing; and different approaches to the legal design of VAT place of taxation rules. The authors offer insightful views on the likely development of new approaches to taxing cross-border digital commerce. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in the first edition and its predecessors, contains a more explicit and systematic consideration of digital commerce issues and the ongoing policy responses to them. Tax professionals and academics everywhere will welcome the important contribution it makes towards the design of cross-border tax rules that are both conceptually sound and practical in application. ‘A tour de force … much larger and richer than its predecessors … a massive contribution to the growing literature on the taxation of e-commerce.’ – Rita de la Feria, British Tax Review ‘Provides important understandings for ongoing policy discussions … I would warmly recommend.’ – P. Rendahl, World Journal of VAT/GST Law
Publisher: Kluwer Law International B.V.
ISBN: 9041167110
Category : Law
Languages : en
Pages : 529
Book Description
Digital commerce – the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services – has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well. This latest edition of the preeminent text on the taxation of digital transactions revises, updates and expands the book’s coverage. It includes a detailed and up-to-date analysis of income tax and VAT developments regarding digital commerce under the OECD and G20 Base Erosion and Profit Shifting (BEPS) reforms. It explores the implications of digital commerce for US state sales and use tax regimes resulting from the 2018 US Supreme Court decision in Wayfair. It discusses cross-border tax in the United States while continuing to focus on tax developments throughout the world. Analysing the practical tax consequences of digital commerce from a multijurisdictional perspective, and using examples to illustrate the application of different taxes to digital commerce transactions, the book offers in-depth treatment of such topics as the following: how tax rules governing cross-border digital commerce are increasingly applied to all cross-border activities; how tax rules and institutional processes have evolved to confront challenges posed by digital commerce; how an emerging ‘tax war’ is developing whereby different countries are unilaterally imposing new tax rules on cross-border digital commerce; how technology enhances tax and cross-border tax information exchanges; how technology reduces both compliance and enforcement costs; cross-border consumption tax issues raised by cloud computing; and different approaches to the legal design of VAT place of taxation rules. The authors offer insightful views on the likely development of new approaches to taxing cross-border digital commerce. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in the first edition and its predecessors, contains a more explicit and systematic consideration of digital commerce issues and the ongoing policy responses to them. Tax professionals and academics everywhere will welcome the important contribution it makes towards the design of cross-border tax rules that are both conceptually sound and practical in application. ‘A tour de force … much larger and richer than its predecessors … a massive contribution to the growing literature on the taxation of e-commerce.’ – Rita de la Feria, British Tax Review ‘Provides important understandings for ongoing policy discussions … I would warmly recommend.’ – P. Rendahl, World Journal of VAT/GST Law
Schwarz on Tax Treaties
Author: Jonathan Schwarz
Publisher: Kluwer Law International B.V.
ISBN: 9403526319
Category : Law
Languages : en
Pages : 870
Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Publisher: Kluwer Law International B.V.
ISBN: 9403526319
Category : Law
Languages : en
Pages : 870
Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
A Research Agenda for Tax Law
Author: Parada, Leopoldo
Publisher: Edward Elgar Publishing
ISBN: 1800885849
Category : Law
Languages : en
Pages : 233
Book Description
This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.
Publisher: Edward Elgar Publishing
ISBN: 1800885849
Category : Law
Languages : en
Pages : 233
Book Description
This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.
Human Rights and Taxation in Europe and the World
Author: Georg Kofler
Publisher: IBFD
ISBN: 9087221118
Category : Human rights
Languages : en
Pages : 581
Book Description
Resumen del editor: "The increasing globalization and the restructuring of the European legal framework by the Treaty of Lisbon are important factors to suggest that the traditional separation of spheres between taxation and human rights should be revisited. This book examines the issues surrounding the impact of the Lisbon Treaty on the guarantee and enforcement of human rights in the area of EU (tax) law and explores the possible development and potential impact of human rights in the field of taxation in this age of global law."
Publisher: IBFD
ISBN: 9087221118
Category : Human rights
Languages : en
Pages : 581
Book Description
Resumen del editor: "The increasing globalization and the restructuring of the European legal framework by the Treaty of Lisbon are important factors to suggest that the traditional separation of spheres between taxation and human rights should be revisited. This book examines the issues surrounding the impact of the Lisbon Treaty on the guarantee and enforcement of human rights in the area of EU (tax) law and explores the possible development and potential impact of human rights in the field of taxation in this age of global law."