Steuerrecht 2008
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Tax Planning With Holding Companies Repatriation Of Us Profits From Europe
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Author : Rolf Eicke
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2009-01-01
Tax Planning With Holding Companies Repatriation Of Us Profits From Europe written by Rolf Eicke 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 2009-01-01 with Law categories.
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Eu Freedoms Non Eu Countries And Company Taxation
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Author : D.S. Smit
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-06-01
Eu Freedoms Non Eu Countries And Company Taxation written by D.S. Smit 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 2012-06-01 with Law categories.
In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Steuerrecht 2008
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Author : Bettina Bärtschi
language : de
Publisher:
Release Date : 2008
Steuerrecht 2008 written by Bettina Bärtschi and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with categories.
Legal Remedies In European Tax Law
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Author : Pasquale Pistone
language : en
Publisher: IBFD
Release Date : 2009
Legal Remedies In European Tax Law written by Pasquale Pistone and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Law categories.
Until now the topic of legal remedies in European direct tax law has been significantly underexposed within the academic tax community. This book aims at filling this gap by providing the typical approaches to European tax law with a general vision on European law, and puts together theory and practice, but also includes contributions on selected relevant issues arising in the protection of taxpayers' rights.
The Taxation Of Permanent Establishments
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Author : Sven Hentschel
language : en
Publisher: Springer Nature
Release Date : 2021-06-26
The Taxation Of Permanent Establishments written by Sven Hentschel and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-26 with Law categories.
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Finance Bundling And Finance Transformation
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Author : Frank Keuper
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-11-13
Finance Bundling And Finance Transformation written by Frank Keuper 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 2013-11-13 with Business & Economics categories.
In managerial literature the challenges of ramping-up, growing and enhancing a (Finance) Shared Services Organization are regularly neglected. Therefore, the compilation will address two objectives: First, based on a generic phase model of an SSO’s development, frequently arising questions related to the management of SSOs shall be systematically discussed and practicable solutions derived. Secondly, a picture of the future of SSOs shall be elaborated, resulting in new future management implications.
Cjeu Case Law In Direct Taxation Territoriality And Fundamental Freedoms
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Author : Stephanie Zolles
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-07-13
Cjeu Case Law In Direct Taxation Territoriality And Fundamental Freedoms written by Stephanie Zolles 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 2023-07-13 with Law categories.
The principle of territoriality and the fundamental freedoms The tension between the fundamental freedoms and the sovereignty of the Member States is omnipresent in the CJEU ́s case law on direct taxation. A significant number of cases concerned one of the core principles in national tax laws: the principle of territoriality. Although this principle is continuously mentioned in cases concerning the compatibility of direct tax measures with the fundamental freedoms, the case law seems to provoke more questions than answers. This book provides guidance on the meaning of territoriality in the CJEU ́s case law on direct taxation as well as on the role which this principle plays in the compatibility of domestic direct tax measures with the fundamental freedoms. During a critical and dogmatically oriented journey through the CJEU ́s case law, the reader can enjoy a comprehensive analysis, containing references to more than 300 cases. Without a doubt, this timeless reflection of the tension between the principle of territoriality and the fundamental freedoms is not only interesting from a dogmatic perspective, but also from a tax policy one.
Traditional And Alternative Routes To European Tax Integration
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Author : Dennis Weber
language : en
Publisher: IBFD
Release Date : 2010
Traditional And Alternative Routes To European Tax Integration written by Dennis Weber 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 Business tax categories.
Tax integration within the European Union can take place in many ways. In this book, various instruments which the Member States and the European Union have available to attain tax integration are discussed and their mutual relationship is studied. The book includes a general report drafted by the editor and is divided into seven parts focusing on (i) Sources of EU law for integration in direct and indirect taxation, (ii) Soft law: Solution or disillusion? Limits?, (iii) Infringement procedures: Another way to move things further?, (iv) Comitology, (v) Relationship between primary and secondary EU law, (vi) VAT Directive tested against primary law, and (vii) Direct tax directives tested against primary law. The book is the outcome of the fourth annual conference of the GREIT (Group for Research on European and International Taxation).
Permanent Establishments
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Author : Ekkehart Reimer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-06-07
Permanent Establishments written by Ekkehart Reimer 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 2018-06-07 with Law categories.
Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
Transfer Pricing And The Arm S Length Principle In International Tax Law
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Author : Jens Wittendorff
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-01-01
Transfer Pricing And The Arm S Length Principle In International Tax Law written by Jens Wittendorff 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 2010-01-01 with Law categories.
The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.