Internationales Steuerrecht In Der Praxis
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Internationales Steuerrecht In Der Praxis
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Author : Robert Rek
language : de
Publisher: Springer-Verlag
Release Date : 2008-08-15
Internationales Steuerrecht In Der Praxis written by Robert Rek and has been published by Springer-Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-08-15 with Business & Economics categories.
Sachverhalte mit Auslandsbezug sind Alltag in deutschen Kanzleien. Das Gebiet des Internationalen Steuerrechts wird jedoch oft unterschätzt und so werden nicht immer die steueroptimalen Entscheidungen in der Beratung getroffen. Das Werk ist der kompakte Ratgeber für das Internationale Steuerrecht.
Praxis Handbuch Der Kapitalgesellschaften
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Author : Irene König (Mag)
language : de
Publisher:
Release Date : 2016
Praxis Handbuch Der Kapitalgesellschaften written by Irene König (Mag) and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016 with categories.
Praxis Handbuch Der Kapitalgesellschaften
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Author : Erika Reinweber
language : de
Publisher:
Release Date : 2007
Praxis Handbuch Der Kapitalgesellschaften written by Erika Reinweber and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with categories.
Cross Border Taxation Of Permanent Establishments
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Author : Andreas Waltrich
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-20
Cross Border Taxation Of Permanent Establishments written by Andreas Waltrich 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 2016-04-20 with Law categories.
The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.
Non Discrimination In Tax Treaty Law And World Trade Law
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Author : Kasper Dziurdź
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-07-23
Non Discrimination In Tax Treaty Law And World Trade Law written by Kasper Dziurdź 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 2019-07-23 with Law categories.
Non-discrimination is a central obligation under both tax treaty and trade law. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work, which explains the policy issues and how non-discrimination analysis works, provides a comprehensive review of non-discrimination rules in WTO and tax treaty law, combining a critical commentary on case law with proposals for an innovative concept for solving cases of discrimination in tax treaty law. Among the practical issues affecting non-discrimination examined in detail are the following: implications that can be drawn from the concepts of non-discrimination under WTO law and Article 24 of the OECD Model; direct and indirect discrimination and analysis of comparability in WTO law and tax treaty law; the MFN and NT rules under the GATT and GATS; the meaning of ‘likeness’ and ‘less favourable treatment’; claiming non-discriminatory tax treatment before tax administrations and courts under a tax treaty; justification of measures against harmful tax competition, low taxation and hybrid mismatch arrangements; thin capitalisation rules, progressive tax rates, foreign losses, group taxation and relief from juridical and economic double taxation under Article 24 of the OECD Model; and integrating a justification defence into any stage of a non-discrimination analysis. The author establishes to what extent formal, substantive and subjective approaches may be applied in a non-discrimination analysis, providing the reasons for the approaches taken. A two-step comparability procedure is applied to selected cases of potential tax discrimination, demonstrating how policy arguments can be addressed under Article 24 of the OECD Model. Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author’s clear explanation of how national law should comply with international obligations. Also, taxpayers’ advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.
Lehrbuch Internationales Steuerrecht
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Author : Kay-Michael Wilke
language : de
Publisher:
Release Date : 2013
Lehrbuch Internationales Steuerrecht written by Kay-Michael Wilke and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with categories.
Hauptbeschreibung Das Standardlehrbuch zum internationalen Steuerrecht! Die Bedeutung des internationalen Steuerrechts nimmt in der steuerlichen Ausbildung und der Berufsprüfung immer mehr zu. Nahezu jedes Jahr werden in Klausuren internationale Sachverhalte abgefragt. Dieses bewährte Lehrbuch versetzt Sie in die Lage, die regelmäßig in der Praxis vorkommenden Fälle des internationalen Steuerrechts zu lösen und Gestaltungsmöglichkeiten zu erkennen. Der Aufbau des Buches orientiert sich an den Bedürfnissen sowohl der Ausbildung als auch der Praxis. Als angehender.
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.
The International Tax Law Concept Of Dividend
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Author : Marjaana Helminen
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-05-02
The International Tax Law Concept Of Dividend written by Marjaana Helminen 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 2017-05-02 with Law categories.
The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Taxation Of International Performing Artistes
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Author : Dick Molenaar
language : en
Publisher: IBFD
Release Date : 2005
Taxation Of International Performing Artistes written by Dick Molenaar 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 Double taxation categories.
The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.
Special Features Of The Un Model Convention
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Author : Anna Binder
language : en
Publisher: Linde Verlag GmbH
Release Date : 2019-10-01
Special Features Of The Un Model Convention written by Anna Binder 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 2019-10-01 with Law categories.
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.