Cahiers de Droit Fiscal International:Limits on the Use of Low-Tax Regimes by Multinational Business: Current Measures and Emerging Trends PDF Download

Author: International Fiscal Association Ifa Staff
Publisher: Springer
ISBN: 9789041116383
Category : Business & Economics
Languages : en
Pages : 960

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Author:
Publisher:
ISBN:
Category : International business enterprises
Languages : en
Pages : 959

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Author: Dennis Weber
Publisher: Kluwer Law International B.V.
ISBN: 9041124020
Category : Law
Languages : en
Pages : 312

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This unique book investigates the extent tot which a taxpayer may invoke the freedom of movement within the Community in order to avoid national direct taxes. A Member State's right to protect its taxing authority and tax jurisdiction may collide with a Union citizen's right to free movement under Community law. The author shows what at the national level is viewed as abuse may often be viewed from an EC law perspective as invoking the Treaty freedoms. As his starting point, the author describes relevant Community law as it stands at present, whereby Member States are exclusively authorized to determine the types, tax bases, rates, and procedural aspects of direct taxes. He goes on to examine the possibilities offered by primary EC law to cross-border taxpayers who seek to avoid tax, basing his presentation on an in-depth analysis of the tax and non-tax case law of the Court of Justice of the European Communities. Among the issues raised in the course of the analysis are the following: applicability of each of the freedoms of the citizen, of goods, of workers, of establishment, of services, and of capital;tests entailed by Community law: the economic activity test, the artificiality test, and the substance test;the extent to which holding and letterbox companies may invoke the freedom of movement; andthe fiscal cohesion justification. The author describes the implicit concept of avoidance that the Court apparently uses by examining its tax and non-tax decisions in avoidance-like cases, thus offering a valuable discussion of whether the anti-abuse doctrine development by the Court is a principle of Community law. In its thorough investigation of a major current manifestation of the emblematic conflict between state taxing authority and personal freedom, this thoughtful and well-researched analysis will be of great value to tax professionals, officials, and academics not only on Europe but wherever this fundamental problem in tax law applies.

Author: International Fiscal Association. Congress
Publisher:
ISBN: 9789083087443
Category :
Languages : en
Pages : 0

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This book provides the general reports, EU report and branch reports of the 74th Congress of the International Fiscal Association (IFA) held in Berlin from 4-8 September 2022.

Author: Richard J. Vann
Publisher:
ISBN: 9789041121554
Category : Law
Languages : de
Pages : 960

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The Panel examines the on-going efforts by governments to keep their company shareholder tax systems competitive with other countries and (where relevant) compliant with international and EC law. In particular the demise of imputation in several countries and its replacement with shareholder relief systems of various kinds is discussed, as well as the recent US proposal to abolish its long standing classical system. In addition to the treatment of dividends, the Panel considers the extent to which the treatment of capital gains on shares in an international setting is now being viewed as part of the company shareholder tax issue.

Author: Mr.Victor Thuronyi
Publisher: International Monetary Fund
ISBN: 9781557755872
Category : Business & Economics
Languages : en
Pages : 534

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Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Author: Prem Kumar Rajaram
Publisher: U of Minnesota Press
ISBN: 1452913234
Category :
Languages : en
Pages : 372

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Connecting critical issues of state sovereignty with empirical concerns, Borderscapes interrogates the limits of political space. The essays in this volume analyze everyday procedures, such as the classifying of migrants and refugees, security in European and American detention centers, and the DNA sampling of migrants in Thailand, showing the border as a moral construct rich with panic, danger, and patriotism. Conceptualizing such places as immigration detention camps and refugee camps as areas of political contestation, this work forcefully argues that borders and migration are, ultimately, inextricable from questions of justice and its limits. Contributors: Didier Bigo, Institut d’Études Politiques, Paris; Karin Dean; Elspeth Guild, U of Nijmegen; Emma Haddad; Alexander Horstmann, U of Münster; Alice M. Nah, National U of Singapore; Suvendrini Perera, Curtin U of Technology, Australia; James D. Sidaway, U of Plymouth, UK; Nevzat Soguk, U of Hawai‘i; Decha Tangseefa, Thammasat U, Bangkok; Mika Toyota, National U of Singapore. Prem Kumar Rajaram is assistant professor of sociology and social anthropology at the Central European University, Budapest, Hungary. Carl Grundy-Warr is senior lecturer of geography at the National University of Singapore.

Author: Gabriel Popescu
Publisher: Rowman & Littlefield
ISBN: 0742556212
Category : Political Science
Languages : en
Pages : 197

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This timely book introduces readers to the central question of borders in the twenty-first century. After familiarizing readers with border thinking and making from antiquity to the present, Gabriel Popescu turns a critical eye on current border-making concepts, processes, and contexts. Throughout, he offers a balanced understanding of borders, explaining why and how interstate borders have emerged, whose interest they serve, who is involved in border making, and how border-making practices affect societies. Assessing the latest theoretical approaches to border studies, the author deftly incorporates a range of disciplinary perspectives, including geography, international relations, sociology, history, security studies, and anthropology. Popescu exploresrecent world events, discussing how current issues such as migration, terrorism, global warming, pandemics, the human rights regime, outsourcing, the economic crisis, supranational integration, regionalization, and digital technology relate to borders andinfluence our lives. Written with a clear eye and voice, this book makes a complex subject accessible to a wide readership.

Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1532

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Author: Sol Picciotto
Publisher: Praeger
ISBN:
Category : Business & Economics
Languages : en
Pages : 424

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This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.