Author: Ruediger Urbahns Publisher: GRIN Verlag ISBN: 3640239148 Category : Law Languages : en Pages : 78
Book Description
Scientific Essay from the year 2008 in the subject Law - Tax / Fiscal Law, grade: keine, language: English, abstract: Translation and commentation of the German Federal Tax Court (Bundesfinanzhof) Decision of 20 August 2008 regarding the classification of an US-LLC (US Limited Liability Company) and introduction into the so called 'analogy comparison' (Typenvergleich) for the classification of foreign companies for German tax purposes(German/English version). The intention of this short compendium is to provide the international tax expert community respectively (tax) managers dealing with international (partnership) cases with a first familiarization with the concept of foreign company classification for German tax purposes based on a so called 'analogy comparison' (Typenvergleich). For this purpose the Bundesfinanzhof decision of 20 August 2008 - regarding the classification of an US-LLC - shall serve as an example and is thus translated and commented in this sense.
Author: Christoph Marchgraber Publisher: Kluwer Law International B.V. ISBN: 9041194118 Category : Law Languages : en Pages : 460
Book Description
Everywhere,new tax rules are under development to engage with the ever-increasing complexity and sophistication of aggressive tax planning and to reverse the tax base erosion it leads to. The most prominent initiative in this context is the Base Erosion and Profit Shifting (BEPS) project of the OECD. Although double non-taxation is among the main issues the BEPS project intends to address, this book shows that this phenomenon has not yet been fully understood. Focusing on the fundamental freedoms and the State aid rules of the EU, this book thoroughly explains the nature of double non-taxation from an EU law perspective, its relation to double taxation, and the impact of EU law on these phenomena. Among the issues dealt with in the course of the analysis are the following: – locating the gaps and inconsistencies among domestic tax systems exploited by taxpayers; – hybrid mismatch arrangements as a prime example of double non-taxation; – political efforts undertaken within the EU in order to address double taxation and double non-taxation; – double non-taxation in the European VAT system; – the convergence of the fundamental freedoms and the State aid rules; – the ECJ’s dilemma with regard to juridical double taxation; – the deviating approach with regard to economic double taxation; – the potential impact of the ECJ’s case law on the EU law compatibility of double non-taxation. The tax jurisprudence of the ECJ is referred to and comprehensively analysed throughout this whole book. A final chapter provides an outlook on possible developments in the future. By providing the first in-depth analysis of EU law’s impact on double non-taxation – and the double taxation relief standards with which it is intimately related – this book takes a giant step towards greater legal certainty in this challenging area of tax law. It will quickly take its place as a major practical analysis which benefits tax authorities, scholars, and tax practitioners across Europe and even beyond.
Author: Mr.Victor Thuronyi Publisher: International Monetary Fund ISBN: 9781557755872 Category : Business & Economics Languages : en Pages : 534
Book Description
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: Publisher: Sweet & Maxwell ISBN: 9780421913301 Category : Business & Economics Languages : en Pages : 682
Book Description
Providing treatment of landlord and tenant matters, this book covers both commercial and residential issues. The reader is informed with the changing complexities of legislation and case law in this area. The coverage of cases and legislation is complemented by practical advice on issues facing practitioners in their daily work
Author: Erika C Collins Publisher: Law Business Research Ltd. ISBN: 1912377683 Category : Languages : en Pages : 1263
Book Description
The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK
Author: Michael Lang Publisher: Linde Verlag GmbH ISBN: 3709408628 Category : Law Languages : en Pages : 266
Book Description
The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Author: Ruediger Urbahns
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Author: Christoph Marchgraber
Author: Mr.Victor Thuronyi
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Author: Erika C Collins
Author: Green Haywood Hackworth
Author: Michael Lang