Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2
DOWNLOAD
Download Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2 PDF/ePub or read online books in Mobi eBooks. Click Download or Read Online button to get Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2 book now. This website allows unlimited access to, at the time of writing, more than 1.5 million titles, including hundreds of thousands of titles in various foreign languages. If the content not found or just blank you must refresh this page
Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2
DOWNLOAD
Author : Dennis Weber
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-09-16
Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2 written by Dennis Weber 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 2024-09-16 with Law categories.
Although still under development, Pillar 2 of the OECD Global Anti-Base Erosion Model Rules is already posing significant challenges for taxation authorities worldwide. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in the field of corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries. This book provides the first in-depth survey of the implications of the Rules for all stakeholders, with detailed annotations by nineteen renowned experts in the field of multinational corporate taxation who describe the relevant provisions with examples and considerations addressing their scope, functioning, and interaction. Undergirded by a comprehensive discussion of the Rules, their technical operation, and the administrative guidance provided by OECD, topics covered include the following: definitions of tax terms for Pillar 2 purposes; computation of income or loss, adjusted covered taxes, effective tax rate, and top-up tax; jurisdictional blending and loss offsets; effect of corporate restructurings and holding structures; excluded categories of income; carve-out opportunities under the Substance-Based Income Exclusion (SBIE); transitional country-by-country and time-limited safe harbours; and differences and interactions between the OECD Global Anti-Base Erosion (GloBE) and both the EU Pillar 2 Directive and the US Global Intangible Low-Taxed Income (GILTI) regimes. It has been estimated that the GloBE reform would produce a worldwide additional tax revenue of USD 200 billion annually. It has thus become imperative for taxation authorities, tax practitioners, and multinational corporate counsel to become as aware as possible of the intricacies of the Pillar 2 Rules, and for this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.
The Global Minimum Tax Selected Issues On Pillar Two
DOWNLOAD
Author : Valentin Bendlinger
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-10-18
The Global Minimum Tax Selected Issues On Pillar Two written by Valentin Bendlinger and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-10-18 with Law categories.
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two
Tax And Technology
DOWNLOAD
Author : Annika Streicher
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-10-13
Tax And Technology written by Annika Streicher and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-10-13 with Law categories.
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.
Introduction To European Tax Law On Direct Taxation
DOWNLOAD
Author : Lukasz Adamczyk
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-09-26
Introduction To European Tax Law On Direct Taxation written by Lukasz Adamczyk and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-09-26 with Law categories.
Basic knowledge of European Tax Law 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.
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law
DOWNLOAD
Author : Valentin Bendlinger
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-10-17
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law written by Valentin Bendlinger 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 2023-10-17 with Law categories.
Rarely in the history of international tax law have there been so many evolutions in such a short space of time: In a dizzying array of reports, work programmes, consultations and announcements, the OECD, with the active support of the EU, has created a framework for a global minimum tax (Pillar Two or GloBE). In the meanwhile, jurisdictions are faced with the practical difficulties of incorporating an incredibly complex set of rules into their domestic legal systems. This book aims to shed light on the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and aims to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties and the EU’s recently adopted GloBE-Directive. The author not only analyses Pillar Two from a technical and a policy perspective but also provides for a comprehensive examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also includes practical examples and illustrates solutions to numerous technical and policy issues of Pillar Two. Among the seminal matters covered are the following: History and Background of the global minimum tax discussion. Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR. Tax policy implications and deficiencies of the final design of Pillar Two. The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties. The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive. The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms. Detailed comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive elucidate common points and deviations. In addition to comprehensive technical considerations, the book also provides a comprehensive tax policy perspective on the global minimum tax. For its unparalleled clarification of the issues alone, this book will prove invaluable to practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two. ‘Valentin Bendlinger’s book is an outstandingly remarkable work on a highly complex topic. The structure, clarity of thinking, and legal argumentation are excellent, and the legal and policy results throughout are profoundly argued. The book successfully ties together broad concepts of international and European (tax) law with highly complex and novel issues of the taxation of multinational enterprises. It should be highlighted that Valentin Bendlinger succeeded in leading the reader from the history and policy through a “jungle” of unprecedented rules to overarching fundamental issues of how the new taxation framework is to be placed in the international and European legal order.’ – Prof. DDr Georg Kofler, LLM (NYU), Vienna University of Economics and Business.
The Pillar Two Global Minimum Tax
DOWNLOAD
Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-08-06
The Pillar Two Global Minimum Tax 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 2024-08-06 with Law categories.
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.
Complexity And Sustainability In Megaprojects
DOWNLOAD
Author : Franca Cantoni
language : en
Publisher: Springer Nature
Release Date : 2024-05-20
Complexity And Sustainability In Megaprojects written by Franca Cantoni and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-05-20 with Science categories.
This book showcases the discussion about megaprojects carried out at the MeRIT (Megaproject Research Interdisciplinary Team) workshop 2023: the crisis, discontinuity, rising prices, and supply chains disruption force radical reflection for those involved in megaprojects. It raises a modern-day challenge, the creation of value for stakeholders. Indeed, the aim of the volume is to encourage readers to think more broadly, articulately and less stringently than the mainstream claims. There is a need to design, implement, and manage megaprojects by abandoning the old paradigm that leveraged solely on time and cost. We need to move beyond that by going to explore the value generated, the positive impact on people, communities and territories. Economic, social and environmental sustainability takes on a new and broader articulation: issues of the circular economy applied to megaprojects are addressed and ample space is ensured for the inclusion of social needs in current practices.
Abuse Of Law In European Taxation
DOWNLOAD
Author : Isabelle Richelle
language : en
Publisher: Springer Nature
Release Date : 2025-05-19
Abuse Of Law In European Taxation written by Isabelle Richelle and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-05-19 with Business & Economics categories.
This book explores the meaning and the impact of the concept of abuse of law in European taxation. Fighting abusive arrangements has gained prominence along three different dimensions: as a methodological tool to constrain access to tax benefits under EU law, as a ground of justification for disadvantageous treatment of cross-border activities and investment, and as a policy goal underlying recent EU tax legislation. The contributors to this book—leading academics and practitioners from different European countries—discuss the most burning issues concerning the prohibition of abuse in tax matters. Starting from a general clarification of notions like ‘tax avoidance’ and ‘aggressive tax planning’ and informed by a deep-diving comparative analysis of the concept of ‘abuse’, the authors examine special anti-avoidance rules both in EU legislation on indirect taxes and under the existing EU corporate tax directives. Furthermore, the authors shed a critical light on the effect of European fundamental freedoms on national anti-abuse provisions. Last but not least the impact of the recently introduced Global Minimum Tax (GloBE) on the operation of anti-abuse rules receives scrutiny. In the end, the book tries to answer whether these different fields of application are informed by a unified notion of fiscal abuse. Given the world-wide momentum behind the fight against fiscal fraud and tax avoidance, the analytical approach of this book, bringing together different strands of legislature and jurisprudence, will be of substantial value for the work of both practitioners and scholars in the field of EU taxation.
Double Non Taxation And The Use Of Hybrid Entities
DOWNLOAD
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.
Taxation Of Derivatives And Cryptoassets
DOWNLOAD
Author : Oktavia Weidmann
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-06-10
Taxation Of Derivatives And Cryptoassets written by Oktavia Weidmann 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 2024-06-10 with Law categories.
Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.