Internationales Steuerrecht
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Tax Planning With Holding Companies Repatriation Of Us Profits From Europe
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Author : Rolf Eicke
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2009-01-01
Tax Planning With Holding Companies Repatriation Of Us Profits From Europe written by Rolf Eicke 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 2009-01-01 with Law categories.
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Internationales Steuerrecht
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Author : Gerrit Frotscher
language : de
Publisher:
Release Date : 2015-04
Internationales Steuerrecht written by Gerrit Frotscher and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-04 with categories.
Taxation In A Global Digital Economy
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Author : Ina Kerschner
language : en
Publisher: Linde Verlag GmbH
Release Date : 2017-10-04
Taxation In A Global Digital Economy written by Ina Kerschner 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 2017-10-04 with Law categories.
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Internationales Steuerrecht
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Author : Harald Schaumburg
language : de
Publisher:
Release Date : 1993
Internationales Steuerrecht written by Harald Schaumburg and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1993 with Aliens categories.
Comprehensive textbook on German international tax law. Included are basic principles, the system of unlimited and limited liability to tax and the domestic and treaty rules for the avoidance of double taxation.
Internationales Steuerrecht
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Author : Tobias Plenk
language : de
Publisher:
Release Date : 2010
Internationales Steuerrecht written by Tobias Plenk and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010 with categories.
Doppelbesteuerungsabkommen
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Author : W. Gassner
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1997-10-15
Doppelbesteuerungsabkommen written by W. Gassner 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 1997-10-15 with Business & Economics categories.
This collection of essays examines the effects of primary European Community Law on tax treaties concluded by the Member States.
Internationales Steuerrecht
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Author : Florian Oppel
language : de
Publisher:
Release Date : 2024
Internationales Steuerrecht written by Florian Oppel and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024 with categories.
Cjeu Case Law In Direct Taxation Territoriality And Fundamental Freedoms
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Author : Stephanie Zolles
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-07-13
Cjeu Case Law In Direct Taxation Territoriality And Fundamental Freedoms written by Stephanie Zolles 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 2023-07-13 with Law categories.
The principle of territoriality and the fundamental freedoms The tension between the fundamental freedoms and the sovereignty of the Member States is omnipresent in the CJEU ́s case law on direct taxation. A significant number of cases concerned one of the core principles in national tax laws: the principle of territoriality. Although this principle is continuously mentioned in cases concerning the compatibility of direct tax measures with the fundamental freedoms, the case law seems to provoke more questions than answers. This book provides guidance on the meaning of territoriality in the CJEU ́s case law on direct taxation as well as on the role which this principle plays in the compatibility of domestic direct tax measures with the fundamental freedoms. During a critical and dogmatically oriented journey through the CJEU ́s case law, the reader can enjoy a comprehensive analysis, containing references to more than 300 cases. Without a doubt, this timeless reflection of the tension between the principle of territoriality and the fundamental freedoms is not only interesting from a dogmatic perspective, but also from a tax policy one.
International Exchange Of Information And The Protection Of Taxpayers
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Author : A. C. M. Schenk-Geers
language : en
Publisher: Kluwer Law International
Release Date : 2009
International Exchange Of Information And The Protection Of Taxpayers written by A. C. M. Schenk-Geers and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Confidential communications categories.
This book focuses on the legal position of the taxpayer in the exchange of tax-related information between states. It begins with the legal-philosophical background of legal protection, which is followed by a description and analysis of the international legal framework for cross-border exchange of information. In the following chapters the attention is paid to the role of the OECD Model Tax Convention, OECD Agreement on Exchange of Information on Tax Matters, the Convention of Strasbourg, the European Directive 77/799 and the Council Regulation 1789/2003. Further, the author examines the interests of the taxpayers and gives outlines for a system of legal protection of taxpayers' right.
Eu Freedoms Non Eu Countries And Company Taxation
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Author : D.S. Smit
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-06-01
Eu Freedoms Non Eu Countries And Company Taxation written by D.S. Smit 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 2012-06-01 with Law categories.
In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.