International Tax Controversies
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International Tax Controversies
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Author : Philip R. West
language : en
Publisher:
Release Date : 2014
International Tax Controversies written by Philip R. West and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Business enterprises categories.
With the U.S. Justice Department taking an ever-closer look at cross-border transactions and their tax implications, the new International Tax Controversies: A Practical Guide provides a detailed roadmap to how to prepare for a tax audit that involves an international component. Creating and retaining the proper transaction-related documentation, and understanding what additional documentation might be needed for an international examination, is vital to a successful audit. International Tax Controversies describes the process of how an international audit proceeds, including providing information on: * How the IRS audit team is chosen * What the limits are of the scope of the examination * The type of examination that will be conducted and the kinds of documents that will need to be provided by the taxpayer and third parties * The kinds of enforcement procedures that may be brought In international tax situations, there are often conflicting positions taken by the U.S. Internal Review Service and a non-U.S. tax authority. Tax treaties containing mutual agreement procedures (MAPs) are often invoked to protect the taxpayer from paying double taxes. International Tax Controversies describes the process by which MAPs may be invoked and a binding resolution created. As most disagreements between international taxing entities involve transfer pricing issues, there is generally an opportunity to obtain an advance pricing agreement (APA) to protect the taxpayer. International Tax Controversies analyzes the APA process, providing a detailed guide on facilitating the process for your client. It also describes the many tax information exchange treaties and agreements that the U.S. has entered into, and the impact they have had on the U.S. taxpayer.
International Tax Controversies
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Author : Philip R. West
language : en
Publisher:
Release Date : 2017-11-07
International Tax Controversies written by Philip R. West and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-11-07 with Law categories.
With the U.S. Justice Department taking an ever-closer look at cross-border transactions and their tax implications, this title provides a detailed roadmap to how to prepare for a tax audit that involves an international component.
International Tax Disputes
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Author : Hans Mooij
language : en
Publisher:
Release Date : 2024-06-28
International Tax Disputes written by Hans Mooij and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-06-28 with Law categories.
Bringing together global experts from diverse legal backgrounds, this comprehensive book offers a rigorous analysis of the complexity of resolving and preventing international tax disputes, covering arbitration, mediation, and dispute management. Analyzing the myriad challenges involved in international tax disputes, this book critically examines the OECD Two Pillar framework, the tax treaty Mutual Agreement Procedures, the OECD MLI arbitration rules, BIT investment arbitration on tax issues, as well as the EU Dispute Resolution Process. Key Features: Written by a team of leading international tax experts Utilizes fresh insights and international perspectives on policy and administration, including viewpoints from emerging economies in Asia and Latin America Outlines the practical strategies tax authorities and multinational corporate taxpayers may use in preventing, managing, and resolving tax disputes, including collaborative compliance Presenting an authoritative overview of international tax disputes, this book will be indispensable to practitioners in corporate and international tax, controversy and dispute specialists, and investment arbitration lawyers. It is also a crucial resource for scholars of tax law, fiscal policy, arbitration, litigation, and dispute resolution.
Dispute Resolution Under Tax Treaties
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Author : Zvi Daniel Altman
language : en
Publisher: IBFD
Release Date : 2005
Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Arbitration and award, International categories.
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
A Global Analysis Of Tax Treaty Disputes
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Author : Eduardo Baistrocchi
language : en
Publisher: Cambridge University Press
Release Date : 2017-08-17
A Global Analysis Of Tax Treaty Disputes written by Eduardo Baistrocchi 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 2017-08-17 with Law categories.
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Brics And International Tax Law
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Author : Peter Antony Wilson
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
Brics And International Tax Law written by Peter Antony Wilson 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 2016-04-24 with Law categories.
With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Resolving Transfer Pricing Disputes
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Author : Eduardo Baistrocchi
language : en
Publisher: Cambridge University Press
Release Date : 2012-12-06
Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi 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 2012-12-06 with Law categories.
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Flexible Multi Tier Dispute Resolution In International Tax Disputes
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Author : Pasquale Pistone
language : en
Publisher:
Release Date : 2020
Flexible Multi Tier Dispute Resolution In International Tax Disputes written by Pasquale Pistone and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with Tax evasion (International law) categories.
Arbitration Under Tax Treaties
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Author : Mario Züger
language : en
Publisher: IBFD
Release Date : 2001
Arbitration Under Tax Treaties written by Mario Züger and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001 with Arbitration and award, International categories.
Analysis of both the concluded and the proposed dispute resolution methods. The relationship between the current developments in tax treaty law and the more general trends of modern dispute resolution in public international law is investigated. Concludes with a summary and evaluation of several alternative methods of dispute resolution in recent treaty practice.
The Public International Law Of Taxation
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Author : Asif H. Qureshi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-22
The Public International Law Of Taxation written by Asif H. Qureshi 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 2019-05-22 with Law categories.
The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.