Proyecto De La Ocde Y Del G 20 Sobre La Erosi N De La Base Imponible Y El Traslado De Beneficios Exigir A Los Contribuyentes Que Revelen Sus Mecanismos De Planificaci N Fiscal Agresiva Acci N 12 Informe Final 2015
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Oecd G20 Base Erosion And Profit Shifting Project Addressing The Tax Challenges Of The Digital Economy Action 1 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 Addressing The Tax Challenges Of The Digital Economy Action 1 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 1.
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.
Residence Of Individuals Under Tax Treaties And Ec Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2010
Residence Of Individuals Under Tax Treaties And Ec Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010 with Domicile in taxation categories.
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.
The International Tax Law Concept Of Dividend
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Author : Marjaana Helminen
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-05-02
The International Tax Law Concept Of Dividend written by Marjaana Helminen 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 2017-05-02 with Law categories.
The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Taxation And Electronic Commerce Implementing The Ottawa Taxation Framework Conditions
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2001-05-04
Taxation And Electronic Commerce Implementing The Ottawa Taxation Framework Conditions 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 2001-05-04 with categories.
This volume provides a comprehensive guide to the status of the OECD-led international work on taxation and electronic commerce, and hence to emerging conclusions and recommendations across a wide span of tax policy and tax administration issues.
Arm S Length Transaction Structures
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Author : Andreas Bullen
language : en
Publisher: IBFD
Release Date : 2011
Arm S Length Transaction Structures written by Andreas Bullen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Corporations categories.
This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).
Langer On Practical International Tax Planning Focus On Tax Planning
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Author : Denis A. Kleinfeld
language : en
Publisher: Practising Law Inst
Release Date : 2000
Langer On Practical International Tax Planning Focus On Tax Planning written by Denis A. Kleinfeld and has been published by Practising Law Inst this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000 with Law categories.
Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.
Tax Amnesties
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Author : Mr.Eric Le Borgne
language : en
Publisher: International Monetary Fund
Release Date : 2008-07-29
Tax Amnesties written by Mr.Eric Le Borgne 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 2008-07-29 with Business & Economics categories.
Tax amnesties remain as popular as ever as a tool for raising revenue and increasing tax compliance. International experience, however, shows that the costs of tax amnesty programs often exceed the programs’ benefits. This paper weighs the advantages and disadvantages of tax amnesties, drawing on results from the theoretical literature, econometric evidence, and selected country and U.S. state case studies. The authors conclude that “successful” tax amnesties are the exception rather than the norm. Improvements in tax administration are the essential ingredient in addressing the main problems that tax amnesties seek to address. Indeed, the most successful amnesty programs rely on improving the tax administration’s enforcement capacity. ?Given the potential drawbacks of tax amnesties, a few alternative measures are discussed.
Democratic Chile
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Author : Kirsten Sehnbruch
language : en
Publisher: Lynne Rienner Pub
Release Date : 2014
Democratic Chile written by Kirsten Sehnbruch and has been published by Lynne Rienner Pub this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Political Science categories.
How was Chile transformed both politically and economically during the two decades of center-left coalition (Concertación) government that followed the country¿s return to democracy in 1990? How did the coalition manage to hold on to power for so long¿but not longer? And were its policies in fact substantially different from those that preceded them? Addressing these questions, the authors of this landmark volume critically assess the successes and failures of Concertación politics and policies in post-Pinochet Chile.
Wage Led Growth
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Author : Engelbert Stockhammer
language : en
Publisher: Springer
Release Date : 2013-12-03
Wage Led Growth written by Engelbert Stockhammer and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-12-03 with Business & Economics categories.
This volume seeks to go beyond the microeconomic view of wages as a cost having negative consequences on a given firm, to consider the positive macroeconomic dynamics associated with wages as a major component of aggregate demand.