Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Report On Pillar Two Blueprint Inclusive Framework On Beps
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The Global Minimum Tax Selected Issues On Pillar Two
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Author : Valentin Bendlinger
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-10-18
The Global Minimum Tax Selected Issues On Pillar Two written by Valentin Bendlinger 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 2024-10-18 with Law categories.
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Economic Impact Assessment Inclusive Framework On Beps
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2020-10-12
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Economic Impact Assessment 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 2020-10-12 with categories.
In May 2019, the Inclusive Framework adopted a Programme of Work, which was endorsed by the G20 Finance Ministers and G20 Leaders in June 2019. The Programme of Work outlined proposals in two pillars that could form the basis for a multilateral consensus-based solution. This report presents an ex ante analysis of the economic and tax revenue implications of the Pillar One and Pillar Two proposals under discussion by the Inclusive Framework as part of its work to address the tax challenges arising from the digitalisation of the economy.
Pillar Two Of The Inclusive Framework On Beps
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Author : Carlo Garbarino
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-09-06
Pillar Two Of The Inclusive Framework On Beps written by Carlo Garbarino and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-09-06 with Law categories.
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law
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Author : Valentin Bendlinger
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-10-17
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law written by Valentin Bendlinger 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 2023-10-17 with Law categories.
Rarely in the history of international tax law have there been so many evolutions in such a short space of time: In a dizzying array of reports, work programmes, consultations and announcements, the OECD, with the active support of the EU, has created a framework for a global minimum tax (Pillar Two or GloBE). In the meanwhile, jurisdictions are faced with the practical difficulties of incorporating an incredibly complex set of rules into their domestic legal systems. This book aims to shed light on the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and aims to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties and the EU’s recently adopted GloBE-Directive. The author not only analyses Pillar Two from a technical and a policy perspective but also provides for a comprehensive examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also includes practical examples and illustrates solutions to numerous technical and policy issues of Pillar Two. Among the seminal matters covered are the following: History and Background of the global minimum tax discussion. Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR. Tax policy implications and deficiencies of the final design of Pillar Two. The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties. The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive. The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms. Detailed comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive elucidate common points and deviations. In addition to comprehensive technical considerations, the book also provides a comprehensive tax policy perspective on the global minimum tax. For its unparalleled clarification of the issues alone, this book will prove invaluable to practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two. ‘Valentin Bendlinger’s book is an outstandingly remarkable work on a highly complex topic. The structure, clarity of thinking, and legal argumentation are excellent, and the legal and policy results throughout are profoundly argued. The book successfully ties together broad concepts of international and European (tax) law with highly complex and novel issues of the taxation of multinational enterprises. It should be highlighted that Valentin Bendlinger succeeded in leading the reader from the history and policy through a “jungle” of unprecedented rules to overarching fundamental issues of how the new taxation framework is to be placed in the international and European legal order.’ – Prof. DDr Georg Kofler, LLM (NYU), Vienna University of Economics and Business.
The Pillar Two Global Minimum Tax
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Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-08-06
The Pillar Two Global Minimum Tax written by Werner Haslehner and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-08-06 with Law categories.
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.
Anti Abuse Rules And Tax Treaties
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Author : Georg Kofler et al.
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-06-24
Anti Abuse Rules And Tax Treaties written by Georg Kofler et al. 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 2024-06-24 with Law categories.
As the struggle to combat tax abuse and tax avoidance gains momentum, ways of making a tax jurisdiction ‘manipulation-proof’ continue to proliferate, from new or revised provisions in model tax treaties to a dramatic increase in the number and variety of anti-abuse and anti-avoidance rules at all levels of government. These measures interact with national tax systems, general anti-abuse clauses and tax treaties. The conflicts and other legal difficulties that inevitably result deserve intensive scrutiny. This book provides an in-depth analysis of current issues concerning the relations of various anti-abuse rules to each other and their impact on the application of tax treaties. The topics include the following: domestic general anti-avoidance rules (GAARs); domestic specific anti-avoidance rules (SAARs) (including controlled foreign company rules); minimum holding periods; indirect transfers of immovable property, shares, and rights; limitation on benefits; residence criteria in tax treaties; tax treatment of sportspersons and entertainers; the principal purpose test of Article 29 (9) OECD Model (2017); and influence of European Union Law on tax treaty abuse. The chapters are revised and expanded versions of papers presented at the 30th Viennese Symposium on International Tax Law held on 12 June 2023 at Vienna University of Economics and Business. Each author offers an in-depth analysis of a particular topic, drawing on the most recent scientific research. This is the only book available to offer such a wide-ranging, detailed, and practical analysis of how the full range of anti-abuse rules interacts with tax treaties. It will prove of immeasurable value to practitioners and law firms active in tax planning, tax consultants, academics and researchers in international tax law and counsel for companies involved in international business.
Tax Transfer Pricing
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Author : Andrea Musselli
language : en
Publisher: Gruppo 24 Ore
Release Date : 2022-09-15T00:00:00+02:00
Tax Transfer Pricing written by Andrea Musselli and has been published by Gruppo 24 Ore this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-09-15T00:00:00+02:00 with Business & Economics categories.
The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
The Resolution Of International Tax Disputes
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Author : David Rüll
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-06-10
The Resolution Of International Tax Disputes written by David Rüll 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 2024-06-10 with Law categories.
The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Tax Compliance And Risk Management
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Author : Piotr Karwat
language : en
Publisher: Taylor & Francis
Release Date : 2023-11-23
Tax Compliance And Risk Management written by Piotr Karwat and has been published by Taylor & Francis this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-11-23 with Law categories.
The concept of tax compliance is as old as the tax itself, but staying compliant with tax regulations has become increasingly demanding. A changing tax regulatory environment, resulting from regulatory actions of the OECD, the European Union and national governments, poses many problems for tax compliance awareness. This book explores various approaches to improving tax compliance. Starting with the procedures and processes that are at the centre of the debate, it includes the level of tax position security obtained as a result of cooperation between tax administration and an organisation, ending with tax compliance requirements imposed by one-sided action of tax administration. Offering an experience and evidence-based analysis of how tax compliance influences an organisation’s tax and financial position, the issues are examined from both a theoretical and a practical perspective, using empirical research and case studies with an international dimension for illustration. Emphasising a holistic approach to tax compliance and its role in tax risk management within an organisation, this study offers a framework for making the challenging task of tax compliance and risk management more effective and more efficient. Exploring tax compliance focusing on the tax world after the BEPS project and anti-tax evasion and anti-tax avoidance regulatory actions undertaken by the European Union and OECD, the book has a practical focus on tax system design within the organisation and will be of interest to students, researchers and practitioners working in the areas of tax law and tax compliance.
Justice Equality And Tax Law
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Author : Nevia Čičin-Šain
language : en
Publisher: Linde Verlag GmbH
Release Date : 2022-10-05
Justice Equality And Tax Law written by Nevia Čičin-Šain 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 2022-10-05 with Law categories.
An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.