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Author: Carlo Romano (juriste).) Publisher: IBFD ISBN: 9076078491 Category : EU Languages : en Pages : 579
Book Description
Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.
Author: Carlo Romano (juriste).) Publisher: IBFD ISBN: 9076078491 Category : EU Languages : en Pages : 579
Book Description
Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.
Author: Yehonatan Givati Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
Advance tax rulings allow taxpayers to achieve certainty about the tax consequences of contemplated transactions, and are thus considered indispensable in the modern world of tax administration and compliance. After providing empirical evidence of tax law uncertainty, which should give rise to a demand for advance tax rulings, the article shows that advance tax rulings are in fact infrequently used. To explain this counterintuitive finding the article analyzes the taxpayers' strategic considerations when deciding whether to request an advance tax ruling. The strategic disadvantages of applying for an advance tax ruling are shown usually to outweigh the strategic advantages of such a request. Since the same strategic considerations apply when taxpayers decide whether to request an advance pricing agreement - a new procedure for resolving transfer pricing disputes - this analysis also explains why, despite considerable attention from scholars and practitioners in recent years, advance pricing agreements have been infrequently used, and are therefore unlikely to resolve the transfer pricing problem - probably the most significant problem in modern international taxation.
Author: John Prebble QC Publisher: ISBN: Category : Languages : en Pages :
Book Description
As commercial transactions and tax law have both become more complex, tax practitioners have called for the establishment of procedures whereby taxpayers can find out in advance the official opinion of the revenue authorities as to the tax implications of their proposed transactions. If formally issued, such opinions should operate as rulings that are binding on the Crown even if they are later discovered to be wrong in law or if the Revenue changes its opinion. This book was written primarily for the purpose of describing and making recommendations for an advance rulings procedure that might be appropriate for New Zealand. It is also a comparative study of advance rulings procedures used in other countries, and in particular, the United States of America, Canada, and Sweden. It contains a draft statutory code. New Zealand adopted a “Determination” system for rulings in respect of loans and other financial arrangements and as a general “Rulings” system for rulings on other areas of the law. Both systems follow the principles that the author advocates.
Author: Mr.Christophe J Waerzeggers Publisher: International Monetary Fund ISBN: 1513511610 Category : Business & Economics Languages : en Pages : 14
Book Description
Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Author: David W. Williams Publisher: ISBN: 9780421570900 Category : Taxation Languages : en Pages : 491
Book Description
Explains the principles underlying the major taxes, and offers an insight into how tax law has developed and is applied. This new edition ignores the detailed and frequently changing provisions found in practitioner texts, aiming to make the principles and
Author: Bert Alink Publisher: Institut für Finanz- und Steuerrecht, Universität Osnabrück ISBN: 3981489470 Category : Law Languages : en Pages : 586
Book Description
Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.
Author: Fatima Chaouche Publisher: Éditions Larcier ISBN: 280791666X Category : Law Languages : en Pages : 525
Book Description
This book is the result of a 4-year research project conducted at the Faculty of Law of the University of Luxembourg. It explores the legal value and enforceability of tax circulars and tax rulings in Luxembourg domestic law in light of the principle of legitimate expectations and related principles. After studying the historical roots of both interpretative acts, this research questions the level of protection taxpayers enjoy when relying on circulars and tax rulings and contains a review of decades of administrative case-law to assess the judicial discourse on taxpayers’ rights to certainty. This book further investigates the case of circulars and tax rulings that contain interpretations of tax laws that are contrary to the law (contra legem) and builds upon the existing normative framework to introduce proposals addressing issues of uncertainty and inequality taxpayers are likely to suffer when relying on such interpretative acts. Prix Pierre Pescatore de la Faculté de Droit de Luxembourg (École doctorale de droit).
Author: Andrea Amatucci Publisher: Kluwer Law International B.V. ISBN: 9041142258 Category : Law Languages : en Pages : 480
Book Description
With a century of solid theory behind it, tax law confronts a new reality: the weakening of the tenacious link between the sovereignty of states and taxation. Yet it is to the continuity of certain themes and principles inherent in the various national tax systems that tax law scholarship continues to look, even as it develops new principles designed to meet the expanding processes of internationalization. This completely updated collection of essays offers an expert comparative analysis, conducted by a sample of the best international tax law scholars, of the fundamental theory of tax law and of the prospects in the near future of tax legislative systems. The emphasis falls naturally on tax theory, jurisprudence, and legislative development in the Member States of the European Union (particularly in Italy, Germany, and Spain), where the process of tax harmonization has been under way for many years. The effect of these processes, via the relevant tax treaties, on the tax systems of Japan and the United States provides a secondary emphasis. Practitioners and academics in tax law will find in this book an invaluable understanding of the challenges that tax law theory strives to meet at this crucial moment in economic history. The essays present a full and reliable exposition of the current theoretical approaches adopted by the various schools of thought in the field, as well as of the main contributions of jurisprudence.
Author: Pasquale Pistone Publisher: IBFD ISBN: 9087220650 Category : Law Languages : en Pages : 573
Book Description
Until now the topic of legal remedies in European direct tax law has been significantly underexposed within the academic tax community. This book aims at filling this gap by providing the typical approaches to European tax law with a general vision on European law, and puts together theory and practice, but also includes contributions on selected relevant issues arising in the protection of taxpayers' rights.
Author: Carlo Romano (juriste).)
Author: Carlo Romano (juriste).)
Author: Yehonatan Givati
Author: John Prebble QC
Author: Mr.Christophe J Waerzeggers
Author: David W. Williams
Author: Bert Alink
Author: Fatima Chaouche
Author: Andrea Amatucci
Author: Pasquale Pistone
Author: Ewa Lotko