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Author: Madalina Cotrut Publisher: ISBN: 9789087223335 Category : Languages : en Pages : 324
Book Description
Tax planning structures used by some MNEs have become the bane of policymakers nowadays, at the OECD as well as the EU level, since recent statistics revealed public budgets were deprived of billions of euros. 0Within the context of recent developments in the tax arena, this book examines the anti-abuse measures that already exist in various countries and scrutinizes the effectiveness of these measures in countering aggressive tax structures. This work can be considered complementary to the reports issued or to be issued by the OECD, and to the recent activity at the EU level, as it provides an in-depth analysis of what is already happening in practice in various countries when they encounter abusive tax structures. It also highlights the challenges implicit in the recommended measures in the draft reports issued by the OECD up until 1 May 2015, with some exceptions. The book provides the reader with an analysis of the most common strategies against tax avoidance; the key concepts in international tax structuring, such as the use of permanent establishments and the exploitation of transfer pricing rules; and the intricacies of anti-abuse measures that counter tax structuring schemes used for financing activities and for selected business models, specifically related to supply chain management, IP migration and exploitation, the digital economy and holding companies.
Author: Madalina Cotrut Publisher: ISBN: 9789087223335 Category : Languages : en Pages : 324
Book Description
Tax planning structures used by some MNEs have become the bane of policymakers nowadays, at the OECD as well as the EU level, since recent statistics revealed public budgets were deprived of billions of euros. 0Within the context of recent developments in the tax arena, this book examines the anti-abuse measures that already exist in various countries and scrutinizes the effectiveness of these measures in countering aggressive tax structures. This work can be considered complementary to the reports issued or to be issued by the OECD, and to the recent activity at the EU level, as it provides an in-depth analysis of what is already happening in practice in various countries when they encounter abusive tax structures. It also highlights the challenges implicit in the recommended measures in the draft reports issued by the OECD up until 1 May 2015, with some exceptions. The book provides the reader with an analysis of the most common strategies against tax avoidance; the key concepts in international tax structuring, such as the use of permanent establishments and the exploitation of transfer pricing rules; and the intricacies of anti-abuse measures that counter tax structuring schemes used for financing activities and for selected business models, specifically related to supply chain management, IP migration and exploitation, the digital economy and holding companies.
Author: OECD Publisher: OECD Publishing ISBN: 9264192743 Category : Languages : en Pages : 91
Book Description
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.
Author: Sergio André Rocha Publisher: Kluwer Law International B.V. ISBN: 9041167080 Category : Law Languages : en Pages : 378
Book Description
The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Author: Madalina Cotrut Publisher: ISBN: 9789087224448 Category : Languages : en Pages :
Book Description
Recent tax developments aimed at mitigating the possibilities of base erosion and profit shifting are expected to increase the importance and popularity of tax incentives. This is due to the fact that states will want to remain competitive on the international stage and multinational enterprises will look for other opportunities to minimize their tax liabilities.0This book seeks to answer the following essential questions, from both a practical and an academic perspective:0- Will tax incentives be the 21st century tool for tax planning structures?0- Will states need to introduce more tax incentives in the future in order to be more competitive?0- What are the effects of the anti-abuse measures adopted by the EU Member States and recommended by the OECD on tax incentives?0- What are the challenges of securing the use of tax incentives?0- What new tax policy challenges will tax incentives bring about? 00This book answers these questions by analysing selected tax incentives that are commonly promoted by both developed and developing states, particularly those tax incentives that are of relevance to corporate income taxation.
Author: Kevin Holmes Publisher: IBFD ISBN: 9087220235 Category : Double taxation Languages : en Pages : 433
Book Description
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Author: Sergio André Rocha Publisher: Kluwer Law International B.V. ISBN: 9041194290 Category : Law Languages : en Pages : 401
Book Description
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
Author: OECD Publisher: OECD Publishing ISBN: 9264162941 Category : Languages : en Pages : 82
Book Description
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author: Richard Krever Publisher: Kluwer Law International B.V. ISBN: 9403506156 Category : Law Languages : en Pages : 314
Book Description
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
Author: Werner C. Haslehner Publisher: ISBN: 9789087226893 Category : Commercial law Languages : en Pages :
Book Description
This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
Author: Tsilly Dagan Publisher: Cambridge University Press ISBN: 1107112109 Category : Business & Economics Languages : en Pages : 263
Book Description
Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.
Author: Madalina Cotrut
Author: Madalina Cotrut
Author: OECD
Author: Sergio André Rocha
Author: Madalina Cotrut
Author: Kevin Holmes
Author: Sergio André Rocha
Author: OECD
Author: Richard Krever
Author: Werner C. Haslehner
Author: Tsilly Dagan