International and Cross-Border Taxation in New Zealand PDF Download

Author: Craig Macfarlane Elliffe
Publisher:
ISBN: 9780864728999
Category : Double taxation
Languages : en
Pages : 765

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Book Description

Author: Craig Elliffe
Publisher:
ISBN: 9781988504995
Category : Business enterprises, Foreign
Languages : en
Pages : 948

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Book Description
Written by international tax law specialist Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand's international tax law and double taxation agreements and transfer pricing regime. The book is designed to provide readers with an understanding of the legal principles and concepts which underpin international tax law and cross-border transactions and with practical guidance designed to assist them to navigate their way through this complex topic. It begins with an introductory chapter explaining the history and concept of international taxation and the way in which New Zealand and other nations deal with international taxation transactions. The next four chapters provide comprehensive coverage of residence-base taxation; source-based taxation; and taxation of source based income. The final two chapters deal with double tax agreements and allocation of profits (thin capitalisation).

Author: Consultative Committee on Full Imputation and International Tax Reform
Publisher: The Treasury, New Zealand
ISBN:
Category :
Languages : en
Pages : 224

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Book Description
The final report of the Consultative Committee on Full Imputation and International Tax Reform. Volume 1 contains recommendations on the further detailed measures required for the operation of the imputation and international tax regimes. Volume 2 sets out the draft legislation.

Author: Leslie Prescott-Haar
Publisher:
ISBN:
Category : Business enterprises, Foreign
Languages : en
Pages : 0

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Book Description

Author: Craig Elliffe
Publisher: Edward Elgar Publishing
ISBN: 180088902X
Category : Law
Languages : en
Pages : 325

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Book Description
In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.

Author: Brendon Barretta
Publisher:
ISBN:
Category :
Languages : en
Pages : 98

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Book Description
International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. Written for the CPA or attorney, the advanced studies cover new theories of international tax planning that fit the changes in E-commerce. Learn about the Google treaty shopping tax plan and the tax savings by placing your website on an offshore computer. This book's international tax strategies will provide your clients with legitimate international tax plans. Using new concepts of trust and company law, you learn advanced cross-border tax planning for E-commerce businesses, importers, and the multi-national family.

Author: Andreas Waltrich
Publisher: Kluwer Law International B.V.
ISBN: 9041168389
Category : Law
Languages : en
Pages : 340

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Book Description
The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.

Author: New Zealand. Consultative Committee on Full Imputation and International Tax Reform
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description

Author: Garth A. Harris
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 476

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Book Description
This book is an authoritative guide to two major aspects of the New Zealand tax system: the rules for taxing income received by its residents from overseas, and those for taxing income received by overseas residents from New Zealand.

Author: Craig Elliffe
Publisher: Cambridge University Press
ISBN: 1108617913
Category : Law
Languages : en
Pages : 355

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Book Description
The question of how to tax multinational companies that operate highly digitalised business models is one of the most contested areas of international taxation. The tax paid in the jurisdictions in which these companies operate has not kept pace with their immense growth and the OECD has proposed a new international tax compromise that will allocate taxing rights to market jurisdictions and remove the need to have a physical presence in the taxing jurisdictions in order to sustain taxability. In this work, Craig Elliffe explains the problems with the existing international tax system and its inability to respond to challenges posed by digitalised companies. In addition to looking at how the new international tax rules will work, Elliffe assesses their likely effectiveness and highlights features that are likely to endure in the next waves of international tax reform.