Oecd Verrechnungspreisleitlinien F R Multinationale Unternehmen Und Steuerverwaltungen 2022
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Oecd Verrechnungspreisleitlinien F R Multinationale Unternehmen Und Steuerverwaltungen 2022
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Author : OECD
language : de
Publisher: OECD Publishing
Release Date : 2022-09-23
Oecd Verrechnungspreisleitlinien F R Multinationale Unternehmen Und Steuerverwaltungen 2022 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 2022-09-23 with categories.
In einer globalen Wirtschaft, die von multinationalen Unternehmen geprägt ist, müssen die Staaten sicherstellen, dass die steuerpflichtigen Gewinne dieser Unternehmen nicht künstlich in andere Steuerhoheitsgebiete verlagert werden und dass die von diesen Unternehmen in ihrem Steuerhoheitsgebiet ausgewiesene Besteuerungsgrundlage der dort ausgeübten wirtschaftlichen Tätigkeit entspricht.
Co Operative Compliance A Framework From Enhanced Relationship To Co Operative Compliance
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2013-07-29
Co Operative Compliance A Framework From Enhanced Relationship To Co Operative Compliance 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 2013-07-29 with categories.
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.
The Creation Of States In International Law
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Author : James R. Crawford
language : en
Publisher: Oxford University Press
Release Date : 2007-03-15
The Creation Of States In International Law written by James R. Crawford and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-03-15 with Law categories.
Statehood in the early 21st century remains as much a central problem as it was in 1979 when the first edition of The Creation of States in International Law was published. As Rhodesia, Namibia, the South African Homelands and Taiwan then were subjects of acute concern, today governments, international organizations, and other institutions are seized of such matters as the membership of Cyprus in the European Union, application of the Geneva Conventions to Afghanistan, a final settlement for Kosovo, and, still, relations between China and Taiwan. All of these, and many other disputed situations, are inseparable from the nature of statehood and its application in practice. The remarkable increase in the number of States in the 20th century did not abate in the twenty five years following publication of James Crawford's landmark study, which was awarded the American Society of International Law Prize for Creative Scholarship in 1981. The independence of many small territories comprising the 'residue' of the European colonial empires alone accounts for a major increase in States since 1979; while the disintegration of Yugoslavia and the USSR in the early 1990s further augmented the ranks. With these developments, the practice of States and international organizations has developed by substantial measure in respect of self-determination, secession, succession, recognition, de-colonization, and several other fields. Addressing such questions as the unification of Germany, the status of Israel and Palestine, and the continuing pressure from non-State groups to attain statehood, even, in cases like Chechnya or Tibet, against the presumptive rights of existing States, James Crawford discusses the relation between statehood and recognition; the criteria for statehood, especially in view of evolving standards of democracy and human rights; and the application of such criteria in international organizations and between states. Also discussed are the mechanisms by which states have been created, including devolution and secession, international disposition by major powers or international organizations and the institutions established for Mandated, Trust, and Non-Self-Governing Territories. Combining a general argument as to the normative significance of statehood with analysis of numerous specific cases, this fully revised and expanded second edition gives a comprehensive account of the developments which have led to the birth of so many new states.
Oecd Guide To Measuring The Information Society 2011
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2011-07-26
Oecd Guide To Measuring The Information Society 2011 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 2011-07-26 with categories.
This Guide to Measuring the Information Society is a compilation of concepts, definitions, classifications and methods for information society measurement and analysis.
E Commerce And Source Based Income Taxation
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Author : Dale Pinto
language : en
Publisher: IBFD
Release Date : 2003
E Commerce And Source Based Income Taxation written by Dale Pinto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003 with Electronic commerce categories.
The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.
Ibfd International Tax Glossary
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Author : Julie Rogers-Glabush
language : en
Publisher:
Release Date : 2015
Ibfd International Tax Glossary written by Julie Rogers-Glabush and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with Taxation categories.
The Federal Income Tax Microform
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Author : Robert Murray 1887-1953 Haig
language : en
Publisher: Legare Street Press
Release Date : 2021-09-09
The Federal Income Tax Microform written by Robert Murray 1887-1953 Haig and has been published by Legare Street Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-09-09 with categories.
This work has been selected by scholars as being culturally important and is part of the knowledge base of civilization as we know it. This work is in the public domain in the United States of America, and possibly other nations. Within the United States, you may freely copy and distribute this work, as no entity (individual or corporate) has a copyright on the body of the work. Scholars believe, and we concur, that this work is important enough to be preserved, reproduced, and made generally available to the public. To ensure a quality reading experience, this work has been proofread and republished using a format that seamlessly blends the original graphical elements with text in an easy-to-read typeface. We appreciate your support of the preservation process, and thank you for being an important part of keeping this knowledge alive and relevant.
Countering Harmful Tax Practices More Effectively Taking Into Account Transparency And Substance Action 5 2015 Final Report
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Author : OCDE,
language : en
Publisher: OCDE
Release Date : 2015-10-12
Countering Harmful Tax Practices More Effectively Taking Into Account Transparency And Substance Action 5 2015 Final Report written by OCDE, and has been published by OCDE this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-12 with Corporations categories.
Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.
Tax Challenges Arising From Digitalisation Interim Report 2018
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Author : Collectif
language : en
Publisher: OECD
Release Date : 2018-05-29
Tax Challenges Arising From Digitalisation Interim Report 2018 written by Collectif and has been published by OECD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-05-29 with Business & Economics categories.
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.
How Fixed Is A Permanent Establishment
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Author : Jean Schaffner
language : en
Publisher:
Release Date : 2013
How Fixed Is A Permanent Establishment written by Jean Schaffner and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Branches (Business enterprises) categories.
Permanent establishment is the key concept for allocating taxation rights in respect of business income. The author discusses the permanent establishment criteria under conditions of e-commerce and the service economy. He shows that the OECD Model Convention and its commentaries already offer the basis for the evolution of the analysis of the concept, and that the preservation of permanent establishment protects and maintains the level playing field between capital importing and capital exporting economies. He examines in depth (I) the prevalence of commercial coherence over geographic coherence, (II) the role of value-added tax, (III) services permanent establishment, (IV) relevant definitions of "activity" and "personnel", (V) multiple permanent establishments, (VI) supervision activity and sub-contracting, (VII) the differences between civil law and common law concepts of representation, (VIII) particular treatment of the insurance sector, (IX) the "force of attraction" concept and (X) and specific exceptions (e.g., transportation, artists and sportsmen, rental income, agricultural activities, pipelines). Taking into account important distinctions between two model conventions (OECD and UN), as well as pertinent EU directives and the impact of EU law, the author proposes minor amendments to the OECD Model that adapt it to economic reality and current trends in jurisprudence and that can be implemented immediately. An appendix includes Article 5 and its commentaries as they have evolved since 1963, with the successive addenda and deletions