Individual Tax Residence
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Residence Of Individuals Under Tax Treaties And Ec Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2010
Residence Of Individuals Under Tax Treaties And Ec 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 2010 with Domicile in taxation categories.
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.
Individual Tax Residence
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Author : Setu Kamal
language : en
Publisher: Sweet & Maxwell
Release Date : 2011
Individual Tax Residence written by Setu Kamal and has been published by Sweet & Maxwell this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Law categories.
This book examines the law relating to individual tax residence. It summarises the rules in statute and common law (including the topical recent high-profile cases). It includes commentary and analysis of this important topic and questions commonly held views as to what steps need to be taken to achieve non-residence
Corporate Residence And International Taxation
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Author : Robert Couzin
language : en
Publisher: IBFD
Release Date : 2002
Corporate Residence And International Taxation written by Robert Couzin and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002 with Conflict of laws categories.
Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.
Jurisdiction To Tax Corporate Income Pursuant To The Presumptive Benefit Principle
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Author : Eva Escribano
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-10
Jurisdiction To Tax Corporate Income Pursuant To The Presumptive Benefit Principle written by Eva Escribano 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 2019-05-10 with Law categories.
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Residence And Domicile Of Individuals
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Author :
language : en
Publisher:
Release Date : 1986
Residence And Domicile Of Individuals written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1986 with categories.
An explanation of the concepts of residence and domicile in UK tax law and their implications for individuals coming to or leaving the UK. Includes appendices summarizing the liability to UK income, capital gains and inheritance taxes of resident, non-resident and non-domiciled individuals.
The Statutory Residence Test For Individuals
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Author : Malcolm Finney
language : en
Publisher:
Release Date : 2015-09-30
The Statutory Residence Test For Individuals written by Malcolm Finney and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-09-30 with categories.
Residence Of Companies Under Tax Treaties And Ec Law
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Author : Guglielmo Maisto (jurist.)
language : en
Publisher: IBFD
Release Date : 2009
Residence Of Companies Under Tax Treaties And Ec Law 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 2009 with Business enterprises categories.
Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.
Manx Income Tax
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Author : Mark Solly
language : en
Publisher:
Release Date : 1992-08-01
Manx Income Tax written by Mark Solly and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992-08-01 with Income tax categories.
Tax Residency Under Domestic Laws
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Author : Nuhu Musa Idris
language : en
Publisher: Eliva Press
Release Date : 2022-08-28
Tax Residency Under Domestic Laws written by Nuhu Musa Idris and has been published by Eliva Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-08-28 with categories.
The author demonstrates that in exercising income tax jurisdiction, the state can choose to have a link with the personality of the income-earner within its territory whether or not the income was derived from a source within its territory (residence-based taxation). No universal rules for determining the tax residence of a person (either natural or juristic) for tax purposes apply in all circumstances. Thus, the states have different definitional rules of residence as contained in their respective income tax legislation and as interpreted by their courts. The global economic integration makes taxpayers move freely and exploit ambiguity created by the divergence of the definition of the tax jurisdiction between the States. The book explores the possibility of achieving cooperation amongst the States in delimiting the scope of their substantive and enforcement tax jurisdiction without losing their sovereignty. The cooperation envisioned by this research is a departure from the traditional approach, where the focal point of achieving cooperation is either bilateral or multilateral tax treaties. The author argues that the cooperation could be achieved through comparative analysis of the definition rule to ascertain the level of convergence and divergence and how they could extend mutual respect for each other's tax sovereignty and balance their interests against that of the taxpayers in defining the tax residence. The book uses Nigeria and South Africa as a case study. Nigeria has adopted the residence-based system at the inception of its income tax system, while South Africa initially adopted the source-base system but later switched to the residence-based system.
Booth And Schwarz Residence Domicile And Uk Taxation
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Author : Jonathan Schwarz
language : en
Publisher: Bloomsbury Publishing
Release Date : 2016-11-21
Booth And Schwarz Residence Domicile And Uk Taxation written by Jonathan Schwarz and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-11-21 with Domicile in taxation categories.
This book provides a comprehensive treatment of the law of residence for tax of individuals, companies, trusts and partnerships in light of the latest legislation, case law and HRMC practice. It analyses the Statutory Residence Test for individuals, split year treatment and temporary non-residence. It includes: domicile and the new deemed domicile to be introduced from 6 April 2017 ; Brexit and its impact on residence ; what is a Scottish taxpayer for the Scottish rate of income tax from April 2016 ; resolution of dual residence ; tax residence for companies ; OECD's Actions 2 and 6 on resolving dual residence of persons other than individuals ; UK case law on residence disputes ; ECJ case law on residence-based discrimination ; resolving residence disputes and appeals ; EU law relating to residence.