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Tax Incentives in the BEPS Era

2018
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Release : 2018
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Book Rating : 448/5 ( reviews)

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Book Synopsis Tax Incentives in the BEPS Era by : Madalina Cotrut

Download or read book Tax Incentives in the BEPS Era written by Madalina Cotrut. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: Recent tax developments aimed at mitigating the possibilities of base erosion and profit shifting are expected to increase the importance and popularity of tax incentives. This is due to the fact that states will want to remain competitive on the international stage and multinational enterprises will look for other opportunities to minimize their tax liabilities.0This book seeks to answer the following essential questions, from both a practical and an academic perspective:0- Will tax incentives be the 21st century tool for tax planning structures?0- Will states need to introduce more tax incentives in the future in order to be more competitive?0- What are the effects of the anti-abuse measures adopted by the EU Member States and recommended by the OECD on tax incentives?0- What are the challenges of securing the use of tax incentives?0- What new tax policy challenges will tax incentives bring about? 00This book answers these questions by analysing selected tax incentives that are commonly promoted by both developed and developing states, particularly those tax incentives that are of relevance to corporate income taxation.

Two Cheers for the Foreign Tax Credit, Even in the BEPS Era

2017
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Release : 2017
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Book Synopsis Two Cheers for the Foreign Tax Credit, Even in the BEPS Era by : J. Clifton Fleming

Download or read book Two Cheers for the Foreign Tax Credit, Even in the BEPS Era written by J. Clifton Fleming. This book was released on 2017. Available in PDF, EPUB and Kindle. Book excerpt: Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this article, we favor worldwide taxation if it is real worldwide taxation - i.e., a non-deferred U.S. tax is imposed on all foreign income of U.S. residents at the time the income in earned. This approach is not acceptable, however, unless the resulting double taxation is alleviated. The longstanding U.S. approach for handling the international double taxation problem is a foreign tax credit limited to the U.S. levy on the taxpayer's foreign income. Indeed, the foreign tax credit is an essential element of the case for worldwide taxation. Moreover, territorial systems often apply worldwide taxation with a foreign tax credit to all income of resident individuals plus the passive income and tax haven income of resident corporations. Thus, the foreign tax credit is actually an important feature of many territorial systems. The foreign tax credit has, however, been subjected to sharp criticisms and Professor Daniel Shaviro has recently proposed replacing the credit with a combination of a deduction for foreign taxes and a reduced U.S. tax rate on foreign income. In this article, we respond to the criticisms and argue that the foreign tax credit is a robust and effective device. Furthermore, we respectfully explain why Professor Shaviro's proposal is not an adequate substitute. We also explore an overlooked aspect of the foreign tax credit - its role as an allocator of the international tax base between residence and source countries - and we explain the credit's effectiveness in carrying out this role. Nevertheless, we point out that the credit merits only two cheers because it goes beyond the requirements of the ability-to-pay principle that underlies use of an income base for imposing tax (instead of a consumption base). On balance, however, the credit is the preferred approach for mitigating international double taxation of income.

Double Non-taxation and the Use of Hybrid Entities

2018-04-18 Law
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Release : 2018-04-18
Genre : Law
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Book Rating : 926/5 ( reviews)

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Book Synopsis Double Non-taxation and the Use of Hybrid Entities by : Leopoldo Parada

Download or read book Double Non-taxation and the Use of Hybrid Entities written by Leopoldo Parada. This book was released on 2018-04-18. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth critique of the BEPS Action Plan 2 with regard to hybrid entities, this timely book provides a critical review of the OECD’s approach and proposes a deeply informed alternative method based on the tax policy aims of simplicity, coherence and ease of administration. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasizing the international tax context, including the application of tax treaties. Among the seminal matters covered are the following: – foundations of the concepts of double non-taxation and hybrid entities, absent of the specific limitations of domestic tax legislation; – extensive analysis based on the rules of characterization of foreign entities for tax purposes in the United States, Spain, Denmark and Germany, as well as on the Poland/United States and Canada/United States tax treaties; – detailed analysis on the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument, especially having in mind the position of developing (source) countries; and – EU tax law as part of the international context, including an extensive analysis on the EU Anti-Tax Avoidance Directive (ATAD) I and ATAD II. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding double non-taxation and hybrid entities, this analysis elaborates solutions applicable to a generality of cases worldwide, and thus hugely promotes the urgent quest for alternative solutions.

Tax Sovereignty in the BEPS Era

2017 International business enterprises
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Release : 2017
Genre : International business enterprises
Kind : eBook
Book Rating : 071/5 ( reviews)

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Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha

Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha. This book was released on 2017. Available in PDF, EPUB and Kindle. Book excerpt: BEPS and the power to tax / Allison Christians -- Tax sovereignty and digital economy in post-BEPS times / Ramon Tomazela Santos & Sergio André Rocha -- Justification and implementation of the international allocation of taxing rights: can we take one thing at a time? / Luís Eduardo Schoueri & Ricardo André Galendi Júnior -- An essay on BEPS / Sovereignty / and Taxation / Yariv Brauner -- Evaluating BEPS / Reuven S. Avi-Yonah & Haiyan Xu -- Jurisdictional excesses in BEPS' times: national appropriation of an enhanced global tax basis / Guillermo O. Teijeiro -- Taxing the consumption of digital goods / Aleksandra Bal -- The birth of a new international tax framework and the role of developing countries / Natalia Quiñones -- The other side of BEPS: "imperial taxation" and "international tax imperialism" / Sergio André Rocha -- Country-by-country over-reporting? national sovereignty, international tax transparency, and the inclusive framework on BEPS / Romero J.S. Tavares -- How are we doing with BEPS recommendations in the EU? / Tomas Balco & Xeniya Yeroshenko -- U.S. tax sovereignty and the BEPS project / Tracy A. Kaye

International Tax Structures in the BEPS Era

2015
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Release : 2015
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Book Rating : 335/5 ( reviews)

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Book Synopsis International Tax Structures in the BEPS Era by : Madalina Cotrut

Download or read book International Tax Structures in the BEPS Era written by Madalina Cotrut. This book was released on 2015. Available in PDF, EPUB and Kindle. Book excerpt: Tax planning structures used by some MNEs have become the bane of policymakers nowadays, at the OECD as well as the EU level, since recent statistics revealed public budgets were deprived of billions of euros. 0Within the context of recent developments in the tax arena, this book examines the anti-abuse measures that already exist in various countries and scrutinizes the effectiveness of these measures in countering aggressive tax structures. This work can be considered complementary to the reports issued or to be issued by the OECD, and to the recent activity at the EU level, as it provides an in-depth analysis of what is already happening in practice in various countries when they encounter abusive tax structures. It also highlights the challenges implicit in the recommended measures in the draft reports issued by the OECD up until 1 May 2015, with some exceptions. The book provides the reader with an analysis of the most common strategies against tax avoidance; the key concepts in international tax structuring, such as the use of permanent establishments and the exploitation of transfer pricing rules; and the intricacies of anti-abuse measures that counter tax structuring schemes used for financing activities and for selected business models, specifically related to supply chain management, IP migration and exploitation, the digital economy and holding companies.

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