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.
Introduction To European Tax Law On Direct Taxation
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Author : Michael Lang
language : en
Publisher:
Release Date : 2018
Introduction To European Tax Law On Direct Taxation written by Michael Lang and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with LAW categories.
"Basic knowledge of European Tax Law Whether student, international tax specialist or european law specialist: "Introduction to European Tax Law on Direct Taxation" is a concise guide to gain basic knowledge of European tax law. This fifth edition has enhanced the analysis of the implications of the EU Charter of Fundamental Rights for direct taxes and significantly revises the structure and content of the chapters on fundamental freedoms and State aid. Further, it has updated all chapters, including numerous developments on mutual assistance in tax matters, added an entirely new chapter on the anti-tax avoidance directive (the so-called ATAD) and supplemented the chapter on dispute settlement with an analysis of the new EU Arbitration Directive. The authors and editors trust that, with its updated content and tools, this book will remain an indispensable tool to consult for even the most experienced European direct tax law experts."--
Hybrid Financial Instruments Double Non Taxation And Linking Rules
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Author : Félix Daniel Martínez Laguna
language : en
Publisher: Kluwer Law International B.V.
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 Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-06-12 with Law categories.
Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
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.
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.
A Guide To The European Vat Directives
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Author : Ben Terra
language : en
Publisher: IBFD
Release Date : 2006
A Guide To The European Vat Directives written by Ben Terra and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with categories.
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 : 2018-04-18
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 2018-04-18 with Law categories.
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.
Eu Anti Tax Avoidance Directive Taxing Payments To U S S Corporations
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Author : G.F. Boulogne
language : en
Publisher:
Release Date : 2020
Eu Anti Tax Avoidance Directive Taxing Payments To U S S Corporations written by G.F. Boulogne and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with categories.
In this article, the authors examine how the EU's second anti-tax-avoidance directive will affect payments from EU entitites to subchapter S corporations in the United States, specifically focusing on the taxation of payments from a Dutch BV (a limited liability company) to a U.S. parent.
Hybrid Mismatch Rules In Luxembourg
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Author : Legitech
language : en
Publisher:
Release Date : 2020-07-07
Hybrid Mismatch Rules In Luxembourg written by Legitech and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-07-07 with categories.
International Taxation In A Changing Landscape
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Author : Jérôme Monsenego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-31
International Taxation In A Changing Landscape written by Jérôme Monsenego 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 2019-05-31 with Law categories.
This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Prof. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax law, with a major focus on corporate taxation, an area to which Prof. Dr Bertil Wiman has dedicated most of his research. The book includes authoritative analyses by acknowledged experts on several key international tax topics, which illustrates the growing complexity of this area together with its rapid evolution. The book contains analyses of key international topics, such as: the tax challenges of the digitalisation of the economy; the resolution of international tax disputes; the principles for the taxation of corporations; EU tax law; transfer pricing; and tax treaty law. The depth of the essays contained in this book mirrors the importance of the contributions of Prof. Dr Bertil Wiman to the international tax community. It will also prove of great value to policymakers, tax practitioners and academics.