Author: Publisher:
ISBN:
Category :
Languages : en
Pages : 1360
Book Description
Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report
Author: OCDE,Publisher: OCDE
ISBN: 9789264241466
Category : International business enterprises
Languages : en
Pages : 70
Book Description
This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports
Records of the the Diplomatic Conference on International Protection of Performers, Producers of Phonograms & Broadcasting Organizations
Author: World Intellectual Property OrganizationPublisher: WIPO
ISBN: 928050634X
Category : Law
Languages : en
Pages : 316
Book Description
The Diplomatic Conference on the International Protection of Performers, Producers of Phonograms and Broadcasting Organizations met in Rome from 10 to 26 October 1961.
Foreign Relations of the United States
Author: United States. Department of StatePublisher:
ISBN:
Category : United States
Languages : en
Pages : 1610
Book Description
The Concept of Permanent Establishment in the Insurance Business
Author: Daniele FrescuratoPublisher: Kluwer Law International B.V.
ISBN: 940353284X
Category : Law
Languages : en
Pages : 430
Book Description
siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Taxation in a Global Digital Economy
Author: Ina KerschnerPublisher: Linde Verlag GmbH
ISBN: 3709409055
Category : Law
Languages : en
Pages : 519
Book Description
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law “Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Foreign Relations of the United States, 1948: Germany and Austria
Author: Public health reports (1881). v. 19 pt. 1 no. 1-26, 1904
Author: Codex Alimentarius
Author: Joint FAO/WHO Codex Alimentarius CommissionPublisher: Food & Agriculture Org.
ISBN: 9789251032718
Category : Technology & Engineering
Languages : en
Pages : 488
Book Description
Public Health Reports
Author: International Taxation of Permanent Establishments
Author: Michael KobetskyPublisher: Cambridge University Press
ISBN: 1139500228
Category : Law
Languages : en
Pages : 469
Book Description
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.