New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations
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New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations
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Author : International Fiscal Association. Congress
language : en
Publisher:
Release Date : 2008
New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations written by International Fiscal Association. Congress and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Corporations categories.
New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations
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Author :
language : en
Publisher:
Release Date : 2008
New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with categories.
New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations
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Author :
language : en
Publisher:
Release Date : 2008
New Tendencies In Tax Treatment Of Cross Border Interest Of Corporations written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with International business enterprises categories.
Tax Treatment Of Interest For Corporations
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Author : Otto Marres
language : en
Publisher: IBFD
Release Date : 2012
Tax Treatment Of Interest For Corporations written by Otto Marres and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Corporations categories.
The tax treatment of interest for corporations continues to engage both tax academics and tax practitioners. In 'Tax Treatment of Interest for Corporations' various aspects of this matter (interest deduction limitations, discriminatory treatment of equity versus debt, preferential tax regimes on group interest income and withholding tax on interest) are dealt with from different perspectives, including economics, tax policy, comparative law, and EU and international law.
Transfer Pricing Aspects Of Intra Group Financing
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Author : Raffaele Petruzzi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2013-10-20
Transfer Pricing Aspects Of Intra Group Financing written by Raffaele Petruzzi 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 2013-10-20 with Law categories.
For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Taxation Of Hybrid Financial Instruments And The Remuneration Derived Therefrom In An International And Cross Border Context
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Author : Sven-Eric Bärsch
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-12-13
Taxation Of Hybrid Financial Instruments And The Remuneration Derived Therefrom In An International And Cross Border Context written by Sven-Eric Bärsch and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-12-13 with Business & Economics categories.
Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.
Corporate Income Taxes Under Pressure
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Author : Ruud A. de Mooij
language : en
Publisher: International Monetary Fund
Release Date : 2021-02-26
Corporate Income Taxes Under Pressure written by Ruud A. de Mooij 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 2021-02-26 with Business & Economics categories.
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
European Union Corporate Tax Law
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Author : Christiana HJI Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2013-05-09
European Union Corporate Tax Law written by Christiana HJI Panayi 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 2013-05-09 with Business & Economics categories.
How do the tax implications of European integration affect companies' cross-border movements and investment strategies?
Corporate Loss Utilisation Through Aggressive Tax Planning
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2011-08-03
Corporate Loss Utilisation Through Aggressive Tax Planning 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 2011-08-03 with categories.
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
Elements Of International Income Taxation
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Author : Philippe Malherbe
language : en
Publisher: Bruylant
Release Date : 2015-05-26
Elements Of International Income Taxation written by Philippe Malherbe and has been published by Bruylant this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-05-26 with Law categories.
Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.
