A Guide To The Anti Tax Avoidance Directive

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A Guide To The Anti Tax Avoidance Directive

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Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-06-26

A Guide To The Anti Tax Avoidance Directive written by Werner Haslehner and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-06-26 with Law categories.

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.

Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05

Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-05 with categories.

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

The Oxford Handbook Of International Tax Law

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Author : Florian Haase
language : en
Publisher: Oxford University Press
Release Date : 2023-10-13

The Oxford Handbook Of International Tax Law written by Florian Haase and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-10-13 with Law categories.

International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.

Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-03-27

Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-03-27 with categories.

This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

Hybrid Financial Instruments Double Non Taxation And Linking Rules

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Author : Félix Daniel Martínez Laguna
language : en
Publisher:
Release Date : 2019-06-12

Hybrid Financial Instruments Double Non Taxation And Linking Rules written by Félix Daniel Martínez Laguna and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-06-12 with categories.

Double non-taxation stemming from hybrid financial instruments and the solutions provided by the OECD and the European Union for tackling such an outcome are the target of this publication. It focuses on the economic and legal features of debt and equity instruments as well as hybrid financial instruments from an interdisciplinary perspective where economics, corporate law, financial accounting law, regulatory law and tax law are present. The different qualification of hybrid financial instruments within and without jurisdictions may lead to double non-taxation across borders, which is one of the main issues of concern to the international tax community.

Introduction To European Tax Law On Direct Taxation

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Author : Michael Lang
language : en
Publisher: Spiramus Press Ltd
Release Date : 2024-12-19

Introduction To European Tax Law On Direct Taxation written by Michael Lang and has been published by Spiramus Press Ltd this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-12-19 with Law categories.

This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. The eighth edition adds new updates on the most essential changes and new case law of the CJEU in the field of European direct taxation. Furthermore, due to its particular importance, the EU Global Minimum Tax Directive is now covered in a separate chapter.

Introduction To European Tax Law Direct Taxation

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Author : Karoline Spies
language : en
Publisher: Spiramus Press Ltd
Release Date : 2023-01-02

Introduction To European Tax Law Direct Taxation written by Karoline Spies and has been published by Spiramus Press Ltd this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-01-02 with Business & Economics categories.

This handbook is a concise guide for all those who aim at obtaining a basic knowledge of European tax law. Designed for students, it should also be useful for experienced international tax specialists with little knowledge of European law, European law specialists who are reluctant to approach the technicalities of direct taxation and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. This book should also help academics without a legal background to approach the technical issues raised by European Union tax law. This edition contains selected relevant information available as of 30 June 2022. It retains all of the features and tools contained in the previous editions (including the final charts, which our readers very much appreciate). In this edition we have also included a list of relevant documents and a selection of reference textbooks on European tax law in five languages, which we found of potential interest to our readers.

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots

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Author : Sebastian Beer
language : en
Publisher: International Monetary Fund
Release Date : 2018-07-23

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots written by Sebastian Beer and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-07-23 with Business & Economics categories.

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

European Union Corporate Tax Law

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Author : Christiana HJI Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2021-06-17

European Union Corporate Tax Law written by Christiana HJI Panayi and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-17 with Business & Economics categories.

What is the impact of European Union law on Member State corporate tax systems and the cross-border activities of companies?

Double Non Taxation And The Use Of Hybrid Entities

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Author : Leopoldo Parada
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-12-11

Double Non Taxation And The Use Of Hybrid Entities written by Leopoldo Parada and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-12-11 with Law categories.

The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. 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 emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation 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; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. 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 hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.