Intra Group Financial Transactions And The Arm S Length Principle A Comparative And Normative Analysis
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Intra Group Financial Transactions And The Arm S Length Principle A Comparative And Normative Analysis
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Author :
language : en
Publisher:
Release Date : 2022
Intra Group Financial Transactions And The Arm S Length Principle A Comparative And Normative Analysis written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022 with categories.
Transfer Pricing Manual
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Author : Gareth Green
language : en
Publisher:
Release Date : 2008-01-01
Transfer Pricing Manual written by Gareth Green and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-01-01 with International business enterprises categories.
Transnational Legal Orders
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Author : Terence C. Halliday
language : en
Publisher: Cambridge University Press
Release Date : 2015-01-19
Transnational Legal Orders written by Terence C. Halliday 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 2015-01-19 with Business & Economics categories.
Transnational Legal Orders offers an empirically grounded approach to the emergence of legal orders beyond nation-states that reframes the study of law and society.
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation
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Author : Aqib Aslam
language : en
Publisher: International Monetary Fund
Release Date : 2021-06-08
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation written by Aqib Aslam and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-08 with Business & Economics categories.
This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.
Tax Arbitrage Through Cross Border Financial Engineering
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Author : Gaspar Lopes Dias V.S.
language : en
Publisher: Kluwer Law International
Release Date : 2015
Tax Arbitrage Through Cross Border Financial Engineering written by Gaspar Lopes Dias V.S. 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 2015 with Law categories.
This book explores tax arbitrage opportunities resulting from financial engineering techniques with cross-border financial instruments such as hybrids, synthetics, and non-traditional financial instruments. Firstly the author clarifies the concept of three kinds of complex financial instruments, and thereafter he discusses the most adequate tax treatment of these instruments in cross-border situations. For this purpose he identifies economic substance as an objective benchmark for the taxation of financial instruments to achieve greater international tax neutrality, and examines the role of the expected return taxation theory. The book also contains a comparative analysis of relevant developments in a number of jurisdictions, including Australia, Belgium, Brazil, Luxembourg, Portugal, UK and USA.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-10
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-07-10 with categories.
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Transfer Pricing And The Arm S Length Principle In International Tax Law
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Author : Jens Wittendorff
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-01-01
Transfer Pricing And The Arm S Length Principle In International Tax Law written by Jens Wittendorff 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 2010-01-01 with Law categories.
The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.
Tax Policy Handbook
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Author : Mr.Parthasarathi Shome
language : en
Publisher: International Monetary Fund
Release Date : 1995-04-25
Tax Policy Handbook written by Mr.Parthasarathi Shome and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 1995-04-25 with Business & Economics categories.
Edited by Parthasarathi Shome, this Handbook was written primarily for economists who are responsible for analyzing and evaluating economic policies of developing countries at an applied level, and who would benefit from a comprehensive discussion of the concepts, principles, and prevailing issues of taxation.
Legal Interpretation Of Tax Law
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Author : Robert F. W. van Brederode
language : en
Publisher:
Release Date : 2014
Legal Interpretation Of Tax Law written by Robert F. W. van Brederode and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Corporations categories.
This book deals comparatively with tax law interpretation in economies engaged in cross-border investment at a global level. Authors from eleven jurisdictions provide detailed analysis and commentary on various tax law topics and issues, such as: methods of tax law interpretation; how the judiciary is organized as regards tax law; the role, if any, of the central goverment's high court in providing precedent and guidelines for interpretation; external sources a court can consider when interpreting legislation; constitutional restrictions on interpretation of legislation; prevalence of the general anti-avoidance rule (GAAR); "transplanted" categories (an undefined term is clarified through the meaning of that same term in another law); the concept of "ordinary income"; the concept of "capital" expenses; interpretation of tax treaties; and interrelation of judicial interpretation and administrative interpretation
The Transformation Of The European Financial System
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Author : Vitor Gaspar
language : en
Publisher:
Release Date : 2003-01-01
The Transformation Of The European Financial System written by Vitor Gaspar and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-01-01 with Banks and banking categories.