Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps

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Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-27

Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps 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 2017-07-27 with 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).

The Political Economy Of Public Finance

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Author : Mustafa Çelen
language : en
Publisher: Ijopec Publication
Release Date : 2017

The Political Economy Of Public Finance written by Mustafa Çelen and has been published by Ijopec Publication this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Political Science categories.

Tax Public Finance And The Rule Of Law

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Author : Dominic de Cogan
language : en
Publisher: Bloomsbury Publishing
Release Date : 2025-02-20

Tax Public Finance And The Rule Of Law written by Dominic de Cogan and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-02-20 with Law categories.

This book offers a key point of reference for reflective and thoughtful examinations of the rule of law in tax and related disciplines. It features a stellar cast of established and early-career researchers from a variety of jurisdictions who have entered into conversations about the nature of the rule of law; its relevance to questions about tax, welfare, distribution and public spending; and the challenges involved in applying legal standards in these fields. There is a particular focus on the interaction between the rule of law and the rapidly emerging world of cross-border tax avoidance, reforms influenced by the OECD's Base Erosion and Profits Shifting project and the evolution of EU-level governance over direct as well as indirect taxes. The book is accessible to those new to taxation and public finance as well as to experts, and to lawyers and non-lawyers alike.

Terra Wattel European Tax Law

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Author : Peter J. Wattel
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-11-20

Terra Wattel European Tax Law written by Peter J. Wattel 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 2018-11-20 with Law categories.

Peter J. Wattel is Advocate General in the Supreme Court of the Netherlands, State Councillor extraordinary in the Netherlands Council of State and professor of EU tax law at the Amsterdam Centre for Tax Law (ACTL), University of Amsterdam. Otto Marres is professor at the ACTL and tax lawyer at Meijburg & Co., Amsterdam. Hein Vermeulen is professor at the ACTL and Director of PwC’s EU Direct Tax Group. The seventh edition of this two-volume set brings a comprehensive and systematic survey of European Tax Law up to January 2018. It provides a state of the art clarification and analysis of the implications of the EU Treaties and secondary EU law for national and bilateral tax law. From the consequences of the EU free movement rights - to the soft law meant to put a halt to harmful tax competition. The seventh edition of European Tax Law offers a cutting-edge analysis of the field surrounding tax law across Europe. It puts forward a thought-provoking discussion of the current EU tax rules, as well as of the EU Court’s case law in tax matters. Previous editions were highly regarded as a staple overview of EU tax law among EU tax law practitioners, policymakers, the judiciary and academics alike. With its updated legislation and case-law up to January 2018, this new edition maintains its unparalleled depth and clarity as the go-to reference book in the field. This first volume of ‘European Tax Law’ extensively covers: 1. The consequences of the EU free movement rights, the EU State aid prohibition, the EU Charter of Fundamental Rights and the general principles of EU law for national tax law, tax treaties, national (tax) procedure, State liability and relations with third States, as they appear from the case law of the Court of justice of the EU 2. Secondary EU law in force and proposed on direct taxes: the Parent-Subsidiary Directive, the Tax Merger Directive, the Interest and Royalties Directive, cross-border tax dispute settlement instruments, the Anti-Tax Avoidance Directive and the C(C)CTB proposal 3. The exchange of information and other administrative assistance in the assessment and recovery of taxes between the EU Member States 4. Soft Law on Harmful Tax Competition 5. Procedural matters and the extent of judicial protection The upcoming second volume of this set will cover harmonization of indirect taxation, energy taxation and capital duty, as well as administrative cooperation in the field of indirect taxation.

European Tax Law Volume 1

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Author : Peter J. Wattel
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-10-23

European Tax Law Volume 1 written by Peter J. Wattel 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 2022-10-23 with Law categories.

Ben Terra (1946–2019) was professor of tax law at the universities of Amsterdam (UvA), the Netherlands, and Lund, Sweden. Peter Wattel is Advocate General in the Supreme Court of the Netherlands, State Councillor extraordinary in the Netherlands, Council of State and professor of EU tax law at the Amsterdam Centre for Tax Law (ACTL), University of Amsterdam. Sjoerd Douma is professor at the ACTL, Director of the Adv LLM programme in International Tax Law at Amsterdam Law School, and partner at Lubbers, Boer & Douma in The Hague. Otto Marres is professor at the ACTL, and tax lawyer at Meijburg & Co., Amsterdam. Hein Vermeulen is Director of PwC’s EU Direct Tax Group, Amsterdam. Dennis Weber is professor of European Corporate Taxation at the ACTL and of counsel at Loyens & Loeff. The eighth edition of this leading textbook brings its comprehensive and systematic survey of European Tax Law up to March 2022. With its critical discussion of the EU tax rules and of the European Court’s case law in tax matters, it surpasses every other textbook on EU Tax Law in its clarification and analysis of the implications of the EU Treaties and secondary EU law for national and bilateral tax law. The in-depth coverage of Volume I includes the following: 1. The far-reaching consequences of the EU free movement rights, the EU State aid prohibition, the EU Charter of Fundamental Rights, and the general principles of EU law for national tax law, tax treaties, national (tax) procedure, State liability, and relations with third States. 2. Secondary EU law in force and proposed on direct taxes (Parent-Subsidiary Directive, Tax Merger Directive, Interest and Royalties Directive, cross-border tax dispute settlement instruments, the Anti-Tax Avoidance Directive and pending company tax proposals). 3. (Automatic) exchange of information and other administrative assistance in the assessment and recovery of taxes between the EU Member States. 4. Soft Law on Harmful Tax Competition. Procedural matters and the extent of judicial protection are emphasized throughout this volume. This new edition will continue to be of immense value to law school and university programmes in (international) tax law and in European Union law and for practice. Volume II (2021) of this book covers harmonization of indirect taxation, energy taxation and capital duty, as well as administrative cooperation in the field of indirect taxation.

Access To Treaty Benefits

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Author : Desiree Auer
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-09-21

Access To Treaty Benefits written by Desiree Auer 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 2021-09-21 with Law categories.

A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.

Structuring Cross Border Transactions

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Author : Mindy Herzfeld
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-10-11

Structuring Cross Border Transactions written by Mindy Herzfeld 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 2022-10-11 with Law categories.

Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.

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.

Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From The Digitalisation Of The Economy Subject To Tax Rule Pillar Two Inclusive Framework On Beps

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2023-07-17

Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From The Digitalisation Of The Economy Subject To Tax Rule Pillar Two Inclusive Framework On Beps 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 2023-07-17 with categories.

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan – the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy – to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy.

I Disallineamenti Da Ibridi

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Author : EUGENIO DELLA VALLE - LUCA MIELE
language : it
Publisher: CEDAM
Release Date : 2021-09-08

I Disallineamenti Da Ibridi written by EUGENIO DELLA VALLE - LUCA MIELE and has been published by CEDAM this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-09-08 with Law categories.

Il fenomeno dei disallineamenti da ibridi cross-border riguarda il sistema di imposizione sul reddito coinvolgendo chiunque produca reddito d’impresa quale che sia la forma, individuale o collettiva. Si tratta di un fenomeno complesso che consiste nello sfruttare le differenze di qualificazione giuridica degli strumenti finanziari o delle entità, incluse le stabili organizzazioni, presenti nelle diverse giurisdizioni, provocando una riduzione della base imponibile nel mercato interno che può derivare da una deduzione di componenti negativi di reddito cui non corrisponde una inclusione nella base imponibile del “beneficiario” o da una doppia deduzione dello stesso componente negativo di reddito in due diverse giurisdizioni. La disciplina anti-ibridi domestica (D.Lgs. n. 142 del 2018) ha natura antielusiva e attua la normativa unionale (direttiva c.d. ATAD 1 siccome integrata dalla direttiva c.d. ATAD 2) che, a sua volta, rinvia al patrimonio interpretativo del Final Report dell’Action 2, ricco di esemplificazioni e di chiarimenti. E proprio in conseguenza di tale rinvio l’innesco della reazione antielusiva va ricercato, più che in principi generali, in una congerie di casi e sottocasi difficilmente gestibili. Di qui l’idea del presente volume che è, quindi, volto a fornire al lettore le coordinate per muoversi all’interno dell’apparato normativo domestico attuativo della disciplina unionale anti-ibridi e delle previsioni di soft law di tipo casistico, non senza trascurare la genesi della disciplina e la sua evoluzione sino alla attuale conformazione.