Cfc Legislation Tax Treaties And Ec Law
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Cfc Legislation Tax Treaties And Ec Law
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2004-01-01
Cfc Legislation Tax Treaties And Ec Law written by Michael Lang 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 2004-01-01 with Law categories.
Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
Tax Treaties And Controlled Foreign Company Legislation Pushing The Boundaries
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Author : Daniel Sandler
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1998-07-29
Tax Treaties And Controlled Foreign Company Legislation Pushing The Boundaries written by Daniel Sandler 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 1998-07-29 with Business & Economics categories.
In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Cfc Legislation
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Author :
language : en
Publisher:
Release Date : 2004
Cfc Legislation written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with categories.
Concept And Implementation Of Cfc Legislation
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Author : Nathalie Bravo
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-09-21
Concept And Implementation Of Cfc Legislation written by Nathalie Bravo 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 2021-09-21 with Law categories.
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
International Tax Planning And Prevention Of Abuse
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Author : Luc De Broe
language : en
Publisher: IBFD
Release Date : 2008
International Tax Planning And Prevention Of Abuse written by Luc De Broe and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Corporations categories.
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Corporations categories.
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
International And Ec Tax Aspects Of Groups And Companies
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Author : Guglielmo Maisto (jurist.)
language : en
Publisher: IBFD
Release Date : 2008
International And Ec Tax Aspects Of Groups And Companies written by Guglielmo Maisto (jurist.) and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Corporations categories.
Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.
Wto And Direct Taxation
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2005-01-01
Wto And Direct Taxation written by Michael Lang 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 2005-01-01 with Law categories.
WTO Law and Direct Taxation are linked in numerous ways. The WTO Agreements, thereof especially the GATT and GATS Agreements, contain several explicit provisions on the subject of direct taxes or even on its delimitation from Tax Treaty Law. To some extent, the scope of application of WTO Law has been broadened by case law to comprise also direct taxes. This entails overlappings particularly with regard to the law of subsidies, prohibitions of discrimination, and most-favoured-nation obligations. This book highlights increasingly relevant interdependencies between WTO Law and Direct Taxation from the viewpoint of 21 States. Special emphasis is placed on the conformity of national taxes on profits with WTO Law as well as on specifics of interpretation in several Member States. 21 National Reports from nearly all EU countries as well as Colombia, Israel, New Zealand, Norway and the USA dealt with this topic and were compiled and published in this volume. Additionally, a General Report prepared by Servatius van Thiel summarises the results of the National Reports. Moreover, experts in this field joining the Conference among them Reuven Avi-Yonah, Michael Lennard and Raymond Luja have volunteered contributions dealing with specific problems of WTO and Direct Taxation.
Eu Tax Law
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Author : Marjaana Helminen
language : en
Publisher: IBFD
Release Date : 2011
Eu Tax Law written by Marjaana Helminen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Direct taxation categories.
This book deals with all the EC law norms that are relevant from the perspective of direct taxes. It explains how these norms are, and should be, interpreted and how they affect national tax laws and the tax treatment in EU Member States. It begins by giving a comprehensive overview of the basic principles and concepts of EC tax law and all relevant articles of the EC Treaty, analysing them in the light of direct tax case law. A discussion follows covering all relevant EC directives and recommendations and other soft law material on direct taxes. Reference is made to all relevant judgments of the EC Court on direct taxes. The book includes a chapter on the tax treatment of the different EU entity forms and the future of corporate taxation, with a separate chapter dedicated to the EC law issues related to transfer pricing and to the EC law norms on administrative assistance in tax matters.
Towards A Homogeneous Ec Direct Tax Law
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Author : Cécile Brokelind
language : en
Publisher: IBFD
Release Date : 2007
Towards A Homogeneous Ec Direct Tax Law written by Cécile Brokelind and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Direct taxation categories.
Issues in 27 member states that might have an impact on their own cases. A new way of thinking is necessary in order to achieve a homogeneous application of non-harmonized community law dealing with direct taxation