Author: Great Britain
Publisher:
ISBN: 9780348240825
Category :
Languages : en
Pages : 0
Book Description
Enabling power: Taxation (International and Other Provisions) Act 2010, s. 164 (4) (b). Issued: 08.11.2022. Sifted: -. Made: 03.11.2022. Laid: 08.11.2022. Coming into force: 01.01.2023. Effect: SI. 2018/266 revoked. Territorial extent & classification: E/W/S/NI. General
The Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2022
Author: Great Britain
Publisher:
ISBN: 9780348240825
Category :
Languages : en
Pages : 0
Book Description
Enabling power: Taxation (International and Other Provisions) Act 2010, s. 164 (4) (b). Issued: 08.11.2022. Sifted: -. Made: 03.11.2022. Laid: 08.11.2022. Coming into force: 01.01.2023. Effect: SI. 2018/266 revoked. Territorial extent & classification: E/W/S/NI. General
Publisher:
ISBN: 9780348240825
Category :
Languages : en
Pages : 0
Book Description
Enabling power: Taxation (International and Other Provisions) Act 2010, s. 164 (4) (b). Issued: 08.11.2022. Sifted: -. Made: 03.11.2022. Laid: 08.11.2022. Coming into force: 01.01.2023. Effect: SI. 2018/266 revoked. Territorial extent & classification: E/W/S/NI. General
TAXATION (INTERNATIONAL AND OTHER PROVISIONS) ACT 2010 TRANSFER PRICING GUIDELINES DESIGNATION... ORDER 2018
Author: GREAT BRITAIN.
Publisher:
ISBN: 9780111166567
Category :
Languages : en
Pages :
Book Description
Publisher:
ISBN: 9780111166567
Category :
Languages : en
Pages :
Book Description
Applying the Arm's Length Principle to Intra-group Financial Transactions
Author: Robert Danon
Publisher: Kluwer Law International B.V.
ISBN: 9403540354
Category : Law
Languages : en
Pages : 1053
Book Description
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Publisher: Kluwer Law International B.V.
ISBN: 9403540354
Category : Law
Languages : en
Pages : 1053
Book Description
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Model Rules of Professional Conduct
Author: American Bar Association. House of Delegates
Publisher: American Bar Association
ISBN: 9781590318737
Category : Law
Languages : en
Pages : 216
Book Description
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Publisher: American Bar Association
ISBN: 9781590318737
Category : Law
Languages : en
Pages : 216
Book Description
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
Author: Organisation for Economic Co-operation and Development
Publisher: Organisation for Economic Co-operation and Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 76
Book Description
Includes 1999 update. 1998 update in back.
Publisher: Organisation for Economic Co-operation and Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 76
Book Description
Includes 1999 update. 1998 update in back.
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol
Author: OECD
Publisher: OECD Publishing
ISBN: 9264115609
Category :
Languages : en
Pages : 112
Book Description
This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.
Publisher: OECD Publishing
ISBN: 9264115609
Category :
Languages : en
Pages : 112
Book Description
This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.
U.S. Tax Guide for Aliens
Individual retirement arrangements (IRAs)
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Individual retirement accounts
Languages : en
Pages : 284
Book Description
Publisher:
ISBN:
Category : Individual retirement accounts
Languages : en
Pages : 284
Book Description
United States Code
Author: United States
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 1506
Book Description
"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 1506
Book Description
"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Guidelines Manual
Author: United States Sentencing Commission
Publisher:
ISBN:
Category : Criminal justice, Administration of
Languages : en
Pages : 556
Book Description
Publisher:
ISBN:
Category : Criminal justice, Administration of
Languages : en
Pages : 556
Book Description