Neutralising The Effects Of Hybrid Mismatch Arrangements Korean Version
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Neutralising The Effects Of Hybrid Mismatch Arrangements Korean Version
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Author : OECD
language : ko
Publisher: OECD Publishing
Release Date : 2015-06-12
Neutralising The Effects Of Hybrid Mismatch Arrangements Korean Version 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 2015-06-12 with categories.
Neutralising The Effects Of Hybrid Mismatch Arrangements Chinese Version
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Author : OECD
language : zh-CN
Publisher: OECD Publishing
Release Date : 2015-06-29
Neutralising The Effects Of Hybrid Mismatch Arrangements Chinese Version 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 2015-06-29 with categories.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report 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 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Neutralising The Effects Of Hybrid Mismatch Arrangements
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Author : Oecd
language : en
Publisher: OCDE
Release Date : 2014-09-16
Neutralising The Effects Of Hybrid Mismatch Arrangements written by Oecd and has been published by OCDE this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-09-16 with Business & Economics categories.
This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-09-16
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements 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 2014-09-16 with categories.
This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.
Neutralising The Effects Of Branch Mismatch Arrangements Action 2
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Author : Organization for Economic Development and Cooperation
language : en
Publisher: Organization for Economic Co-Operation & Development
Release Date : 2017
Neutralising The Effects Of Branch Mismatch Arrangements Action 2 written by Organization for Economic Development and Cooperation and has been published by Organization for Economic Co-Operation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Corporations categories.
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings 5th Edition
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Author : Peter H. Blessing
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-03-10
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings 5th Edition written by Peter H. Blessing 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 2020-03-10 with Law categories.
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon
International Taxation Of Trust Income
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Author : Mark Brabazon
language : en
Publisher: Cambridge University Press
Release Date : 2019-05-02
International Taxation Of Trust Income written by Mark Brabazon 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 2019-05-02 with Law categories.
This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Transfer Pricing In Manufacturing
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Author : Ioana Ignat
language : en
Publisher: Springer Nature
Release Date : 2022-05-09
Transfer Pricing In Manufacturing written by Ioana Ignat and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-05-09 with Business & Economics categories.
Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter “TAMSAT” is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings
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Author : Ansgar A. Simon
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-08-31
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings written by Ansgar A. Simon 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 2023-08-31 with Law categories.
This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.