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Author: Xavier Oberson Publisher: IBFD ISBN: 9087220987 Category : Double taxation Languages : en Pages : 457
Book Description
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author: Xavier Oberson Publisher: IBFD ISBN: 9087220987 Category : Double taxation Languages : en Pages : 457
Book Description
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author: United States. Congress. Senate. Committee on Foreign Relations Publisher: ISBN: Category : Convention Between the United States of America and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income Languages : en Pages : 94
Author: Xavier Oberson Publisher: Edward Elgar Publishing ISBN: 1786434733 Category : Disclosure of information Languages : en Pages : 335
Book Description
The financial crisis of 2008 and the emergence of various scandals around the world sparked a movement towards greater transparency with international exchange of information in tax matters. Fully revised and updated, this book considers the emergence of a new global standard, the automatic exchange of information. Providing a comprehensive overview of the main developments, it analyses the structure and content of the various existing instruments and models, taking into account the most up to date developments.
Author: Jonathan Schwarz Publisher: Kluwer Law International B.V. ISBN: 9403526319 Category : Law Languages : en Pages : 870
Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Author: Johannes Köppel Publisher: Graduate Institute Publications ISBN: 2940415749 Category : Law Languages : en Pages : 55
Book Description
The story broke in 2006: Since 9/11, US intelligence services have had access to practically any international money transfer data by infiltrating the SWIFT (Society for Worldwide Interbank Financial Telecommunication) network. Banks worldwide transfer money orders and personal customer data through this network. While the surveillance was all-embracing in 2001, it was gradually limited over the course of the last few years. Revealed by the New York Times, the SWIFT affair has had global as well as national implications. While this dissertation first examines the international dimension of the SWIFT surveillance, the analysis mainly focuses on the national repercussions for Switzerland. Arditi Prize 2010 in International Affairs.
Author: Henri B. Meier Publisher: Springer Nature ISBN: 3031231945 Category : Business & Economics Languages : en Pages : 639
Book Description
How could a small country in the middle of Europe, surrounded by much bigger countries and economic giants like Germany and France and in direct competition with North American and Asian rivals, develop world-class, cutting-edge financial markets? Swiss Finance answers this question, separating myth from reality, by explaining how Switzerland managed dramatic pressures brought to bear on its financial markets during the past two decades, perhaps none of them so great as the: · Competitive challenges caused by changes in Switzerland's banking secrecy laws and practices, · Shifting tide of new wealth generation toward Asia (e.g., China, Singapore, and South Korea), · Burdensome federal stamp and withholding taxes, and · Digitalization of the financial services industry, including cybersecurity, cryptocurrencies, smart contracts, central bank digital currencies, the FinTech revolution, and DLT applications. Swiss Finance thoroughly analyzes Swiss financial markets’ successes and challenges. It covers critical topics for practitioners and academics to fully understand this unique development in world financial markets and private wealth administration.
Author: United States. Congress. Senate. Committee on Foreign Relations Publisher: ISBN: Category : Convention Between the United States of America and the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Languages : en Pages : 104
Author: Xavier Oberson
Author: Xavier Oberson
Author: United States. Congress. Senate. Committee on Foreign Relations
Author: Xavier Oberson
Author: Jonathan Schwarz
Author: 
Author: Switzerland
Author: Switzerland
Author: Johannes Köppel
Author: Henri B. Meier
Author: United States. Congress. Senate. Committee on Foreign Relations