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The Spotlight on BEPS

2018
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Release : 2018
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Book Synopsis The Spotlight on BEPS by : Michael D'Ascenzo

Download or read book The Spotlight on BEPS written by Michael D'Ascenzo. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: In recent times mainstream media has put the spotlight on corporate tax affairs. The underlying concern is double non-taxation: that is, that some multinationals are not paying tax on their business profits anywhere in the world - particularly technology companies and firms with high levels of intangible property. This phenomenon of 'stateless income' raises issues of fairness, tax base protection and efficiency. However, to the extent that no country receives its fair share of tax revenue, the problem is broader than a particular structure, industry or country. Base Erosion and Profit Shifting (BEPS) which produces this outcome questions whether the principles underpinning sovereign taxing rights and their allocation under treaties are fit for purpose in today's global and digital business environment. What is of significance is that the debate over BEPS has reached the political level. Organisations such as the OECD and many countries around the world are now actively involved in what is likely to be an extended review of the architecture and integrity of the framework for international taxation.

The New Permanent Establishment

2023-04-21 Law
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Release : 2023-04-21
Genre : Law
Kind : eBook
Book Rating : 016/5 ( reviews)

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Book Synopsis The New Permanent Establishment by : Tiago Gonçalves Marques

Download or read book The New Permanent Establishment written by Tiago Gonçalves Marques. This book was released on 2023-04-21. Available in PDF, EPUB and Kindle. Book excerpt: This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.

A Multilateral Convention for Tax

2021-11-29 Law
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Release : 2021-11-29
Genre : Law
Kind : eBook
Book Rating : 290/5 ( reviews)

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Book Synopsis A Multilateral Convention for Tax by : Sergio André Rocha

Download or read book A Multilateral Convention for Tax written by Sergio André Rocha. This book was released on 2021-11-29. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.

Hybrid Entities in Tax Treaty Law

2020-09-03 Law
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Release : 2020-09-03
Genre : Law
Kind : eBook
Book Rating : 754/5 ( reviews)

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Book Synopsis Hybrid Entities in Tax Treaty Law by : Sriram Govind

Download or read book Hybrid Entities in Tax Treaty Law written by Sriram Govind. This book was released on 2020-09-03. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.

Transfer Pricing Developments Around the World 2019

2019-08-09 Law
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Release : 2019-08-09
Genre : Law
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Book Rating : 830/5 ( reviews)

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Book Synopsis Transfer Pricing Developments Around the World 2019 by : Michael Lang

Download or read book Transfer Pricing Developments Around the World 2019 written by Michael Lang. This book was released on 2019-08-09. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based papers prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on Transfer Pricing and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. The intense work of international organizations such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

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