The Essential GAAR Manual PDF Download

Author: William I. Innes
Publisher: CCH Canadian Limited
ISBN: 9781553676195
Category : Income tax
Languages : en
Pages : 316

View

Book Description

Author:
Publisher:
ISBN:
Category : Annotations and citations (Law)
Languages : en
Pages : 300

View

Book Description
"Formerly known as the International Citation Manual"--p. xv.

Author: Werner Haslehner
Publisher: Edward Elgar Publishing
ISBN: 178990577X
Category : Law
Languages : en
Pages : 364

View

Book Description
This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.

Author: Eva Escribano
Publisher: Kluwer Law International B.V.
ISBN: 940350644X
Category : Law
Languages : en
Pages : 254

View

Book Description
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Author: CCH Canadian Limited
Publisher: Don Mills, Ont. : CCH Canadian
ISBN:
Category : Corporations
Languages : en
Pages : 358

View

Book Description
The 1987 tax reform package considered.

Author: Christiana HJI Panayi
Publisher: Bloomsbury Publishing
ISBN: 1849469547
Category : Law
Languages : en
Pages : 373

View

Book Description
This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world.

Author: Valeria Gontareva
Publisher: AuthorHouse
ISBN: 1728353823
Category : Business & Economics
Languages : en
Pages : 342

View

Book Description
“This is an extraordinary book from an extraordinary person. This book is an insightful, candid and passionate account of her approach and policy experience. She has called it a ‘Practical Manual’ for reforms – it is that but also much more: a historical record of reforms against all odds.” – Erik Berglof, Director of LSE Institute of Global Affairs “Many emerging economies often lack practical experience in transforming themselves into fully-functioning market-oriented economies and this Practical Manual will help you with this task. Moreover, the book is precisely about how to accomplish drastic reforms in wartime – and I truly believe that the wartime of COVID-19 is an unprecedented opportunity for reform.” – Valeria Gontareva, Former Governor of the National Bank of Ukraine In addition, Valeria received a nomination for her work as the Governor of the National Bank of Ukraine in the Financial Times’s Women of the Year 2019 list.

Author: Peter Harris
Publisher: Cambridge University Press
ISBN: 9780521853118
Category : Law
Languages : en
Pages : 520

View

Book Description
Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.

Author: Hilary Cooper
Publisher: Cambridge University Press
ISBN: 1009005200
Category : Business & Economics
Languages : en
Pages : 449

View

Book Description
Reveals the deep roots of the UK's lack of resilience when COVID-19 hit and sets out an ambitious manifesto for change.

Author: William R. Lederman
Publisher: Osgoode Hall law School, York University
ISBN:
Category : Law
Languages : en
Pages : 272

View

Book Description