Reconstructing The International Tax System

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Reconstructing The International Tax System

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Author : Elizabeth Rosenthal
language : en
Publisher: Springer Nature
Release Date : 2025-05-27

Reconstructing The International Tax System written by Elizabeth Rosenthal and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-05-27 with Business & Economics categories.

Source-based taxation and the arm’s length standard have been foundational elements of the international tax system for many decades. With the advent of the highly digitalized platform firm, the OECD and many other stakeholders assert that these principles have been rendered obsolete. In their stead, these stakeholders have proposed an alternative hybrid international tax system. Under this proposed hybrid system, the long-standing profit allocation rules would be applied in the first instance to determine the preliminary attribution of in-scope multinational firms’ taxable income to individual taxing jurisdictions. These results would then be subject to a secondary reallocation designed to ensure that a portion of such firms’ taxable income is attributed to, and taxable by, jurisdictions in which consumers and users reside (“market jurisdictions”). This secondary allocation – the core of the OECD’s Pillar One and an essential element of its two-pronged “Pillar One-Pillar Two Solution” – explicitly deviates from both the arm’s length standard and the principle of source-based taxation. For many reasons, examined in this book, the OECD’s Pillar One would not provide for the effective taxation of highly digitalized platform firms, and, by extension, it would not stabilize the international tax system. The author argues that source-based taxation and the arm’s length standard are entirely compatible with the attribution of a portion of highly digitalized platform firms’ taxable income to market jurisdictions. However, new transfer pricing methodologies and a revised definition of ‘control’ for transfer pricing purposes are required to achieve this result. Combining important findings and insights from academic research in a variety of fields with the author’s extensive practical experience in both public and private spheres, this book is appropriate for academics as well as private sector advisors in the fields of transfer pricing and international tax, chief financial officers of multinational corporations and tax policy analysts.

Reconstructing The Global Political Economy

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Author : Andersson, Erik
language : en
Publisher: Bristol University Press
Release Date : 2020-05-20

Reconstructing The Global Political Economy written by Andersson, Erik and has been published by Bristol University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-05-20 with Political Science categories.

In an era of post-globalisation, the global political economy needs restructuring. This future-orientated textbook examines the challenges facing the world economy as a result of climate change, social and economic inequality and provides future-oriented solutions. Andersson clearly presents and explains key concepts from Global Political Economy (GPE) to show how these can be used to design and analyse potential reconstructions of the global political economy, offering the analytical tools and inroads to this reconstruction. With a comprehensive exploration of the different ideological pathways that change might take, through intersecting dimensions of gender, race and class, the author expertly guides the reader through thematic chapters such as: • The political economy of everyday life • Regulation of global trade • Post-development • Global value chain production • Financial markets This textbook will help students and non-specialist readers to see that global economic change is possible and show how core concepts from GPE can enable clear thinking about a global future that is environmentally, socially and economically sustainable.

International Law And Post Conflict Reconstruction Policy

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Author : Matthew Saul
language : en
Publisher: Routledge
Release Date : 2015-05-15

International Law And Post Conflict Reconstruction Policy written by Matthew Saul and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-05-15 with Law categories.

The trend for international engagement in post-conflict reconstruction has produced a host of best-practice postulates on topics such as local involvement in decision-making, accountability for past atrocities, sensitivity to context, and the construction of democratic institutions of governance. International law has potential relevance for many of these themes, yet the question of how the implementation of best-practice policy recommendations might be affected by international law remains under-examined. This book offers a fuller understanding of the role of international law in the practice of post-conflict reconstruction. It explores how international legal issues that arise in the post-conflict period relate to a number of strands of the policy debate, including government creation, constitution-making, gender policy, provision of security, justice for past atrocities, rule of law development, economic recovery, returning displaced persons, and responsibilities of international actors. The chapters of the book work to reveal the extent to which international law figures in the policy of internationally enabled post-conflict reconstruction across a range of sectors. They also highlight the scope for international law to be harnessed in a more effective manner from the perspective of the transition to peace and stability. The book lays out a basis for future policy making on post-conflict reconstruction; one that is informed about the international legal parameters, and more aware of how international law can be utilized to promote key objectives.

Reconstructing Afghanistan

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Author : International Monetary Fund
language : en
Publisher: International Monetary Fund
Release Date : 2005-04-15

Reconstructing Afghanistan written by International Monetary Fund 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 2005-04-15 with Business & Economics categories.

This book, which reflects the IMF staff's work in Afghanistan from early 2002 through the first quarter of 2004, provides an overview of the institutional and economic achievements in Afghanistan in the post-Taliban period, that is, from late 2001 to early 2004. During this period, the staff focused on helping (often under difficult circumstances) the Afghan authorities quickly establish abasic framework for economic management and policies, including rebuilding key institutions. Reconstructing Afghanistan describes the strong economic recovery that took place during 2002 and 2003; traces the formulation and implementation of the government’s budgetary policy; discusses the progress made in rebuilding fiscal institutions; and outlines the challenges and issues that the authorities faced in the area of monetary and exchange rate policy.

International Business Taxation

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Author : Sol Picciotto
language : en
Publisher: Praeger
Release Date : 1992-03-02

International Business Taxation written by Sol Picciotto and has been published by Praeger this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992-03-02 with Business & Economics categories.

This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

The International Taxation System

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Author : Andrew Lymer
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-12-06

The International Taxation System written by Andrew Lymer 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 2012-12-06 with Business & Economics categories.

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

International Taxation Of Permanent Establishments

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Author : Michael Kobetsky
language : en
Publisher: Cambridge University Press
Release Date : 2011-09-15

International Taxation Of Permanent Establishments written by Michael Kobetsky 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 2011-09-15 with Law categories.

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots

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Author : Sebastian Beer
language : en
Publisher: International Monetary Fund
Release Date : 2018-07-23

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots written by Sebastian Beer 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 2018-07-23 with Business & Economics categories.

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

The International Politics Of Post Conflict Reconstruction In Guatemala

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Author : N. Short
language : en
Publisher: Springer
Release Date : 2016-04-30

The International Politics Of Post Conflict Reconstruction In Guatemala written by N. Short and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-30 with Political Science categories.

This book looks at the Guatemalan peace process, which was successful in providing a development program to modernize the economy and national infrastructure with the support of international organizations and negotiating parties, analyzing the extent to which peace processes offer opportunity for progressive social transformation.

Combating Tax Avoidance In The Eu

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Author : José Manuel Almudí Cid
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-12-20

Combating Tax Avoidance In The Eu written by José Manuel Almudí Cid 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 2018-12-20 with Law categories.

Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.