Taxation Of Bilateral Investments
DOWNLOAD
Download Taxation Of Bilateral Investments PDF/ePub or read online books in Mobi eBooks. Click Download or Read Online button to get Taxation Of Bilateral Investments book now. This website allows unlimited access to, at the time of writing, more than 1.5 million titles, including hundreds of thousands of titles in various foreign languages. If the content not found or just blank you must refresh this page
Taxation Of Bilateral Investments
DOWNLOAD
Author : Carlo Garbarino
language : en
Publisher:
Release Date : 2019
Taxation Of Bilateral Investments written by Carlo Garbarino and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Corporations categories.
This book provides an overview of counter-BEPS) (base erosion and profit shifting) measures in the OECD Model and Commentary, and aims to provide a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties. It includes practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment. It explores specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and Commentary, and explains how BEPS treaty rules affect a range of corporate tax strategies including PE, use of corporate vehicles and intra-group transactions. It provides information on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement, focussing on tax treaty issues induced by the BEPS Project. The book has four chapters: (1) doing business through a PE; (2) entitlement to treaties; (3) operating through corporate vehicles; and (4) dispute settlement and enforcement.
The Impact Of Bilateral Investment Treaties On Taxation
DOWNLOAD
Author : Michael Lang
language : en
Publisher:
Release Date : 2017
The Impact Of Bilateral Investment Treaties On Taxation written by Michael Lang and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with categories.
The tax aspects of bilateral investment treaties, which, in most cases, provide the investor with the unique opportunity to directly initiate an international dispute settlement process? also known as investor-state dispute settlement? are often overlooked. The increasing number of tax-related investment disputes is a clear indicator of an urgent need to identify and examine the issues emerging in this area in an academic context.0 The aim of this book is to provide a comprehensive analysis of the relationship between taxation and bilateral investment treaties. Twenty-one national reports from countries across the globe have been compiled in this volume. The reports, prepared for the conference?The Impact of Bilateral Investment Treaties on Taxation?, which took place in Rust (Austria) from 2-4 July 2015, help bring to light tax aspects of bilateral investment treaties that have significant unexplored aspects.
The Effect Of Treaties On Foreign Direct Investment
DOWNLOAD
Author : Karl P Sauvant
language : en
Publisher: Oxford University Press
Release Date : 2009-03-27
The Effect Of Treaties On Foreign Direct Investment written by Karl P Sauvant 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 2009-03-27 with Law categories.
Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
The Effect Of Treaties On Foreign Direct Investment
DOWNLOAD
Author : Karl P. Sauvant
language : en
Publisher:
Release Date : 2009
The Effect Of Treaties On Foreign Direct Investment written by Karl P. Sauvant and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Double taxation categories.
In recent years, the treaties and strategies promoting global investment have changed dramatically. This book is a comprehensive assessment of the performance of these treaties. It presents the most recent literature on BITs and DTTs as well as their impact on foreign investments.
Taxation Of Bilateral Investments
DOWNLOAD
Author : Carlo Garbarino
language : en
Publisher: Edward Elgar Publishing
Release Date : 2019
Taxation Of Bilateral Investments 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 2019 with Corporations categories.
The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.
The State S Power To Tax In The Investment Arbitration Of Energy Disputes
DOWNLOAD
Author : Cornel Marian
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-09-28
The State S Power To Tax In The Investment Arbitration Of Energy Disputes written by Cornel Marian 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 2020-09-28 with Law categories.
The State’s Power to Tax in the Investment Arbitration of Energy Disputes Outer Limits and the Energy Charter Treaty Cornel Marian States today are expected not only to regulate the efficient and safe production and distribution of energy to end-users but also to incentivize increased production of energy and the transition to clean energy. In recent years, states are increasingly relying on taxation measures to address the economic challenges affecting the energy sector. This book provides the first in-depth exploration of the intersection between the treaty investment protection regime and taxation measures, as these materialize in investor-state energy disputes. With the analysis of all known and pending cases under the Energy Charter Treaty (ECT), as well as non-ECT cases and bilateral investment treaties which have heavily influenced ECT jurisprudence, the author develops a deeply informed energy tax policy that greatly mitigates the points of tension in the current regime. He closely investigates the following elements of the subject: aligning the ECT Taxation Article with the taxation articles of other investment treaties; tracing current case law to the original arbitration decisions involving tax measures; extrapolating the interplay of taxation provisions with substantive standards of investment protection as reviewed by international arbitral tribunals; evaluating the outer limits of the state’s power to tax under investment treaties and public international law; and addressing how the Yukos arbitration case has changed the framework of taxation issues in investment arbitration. In a clear and concise manner, the author provides the necessary framework to dissect any taxation chapter of an investment treaty and presents tools for the development of long-term tax policy and the adoption of model taxation clauses for sustainable investment protection mechanisms. The book takes a giant step toward meeting the ECT’s mandate to promote long-term cooperation in the energy field with a set of defined objectives focusing on trade, cooperation, energy efficiency, and environmental protection. It will be of immeasurable value to states in developing tax-specific investment incentive schemes as well as to investors in completing a necessary level of due diligence against possible adverse tax measures. Practitioners and academics with a focus on international arbitration will benefit from the book’s systematic approach to the complex taxation provisions of investment protection treaties and more readily recognize the “red flags” attached to national taxation provisions and their impact on investments in the energy sector.
Brics And International Tax Law
DOWNLOAD
Author : Peter Antony Wilson
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
Brics And International Tax Law written by Peter Antony Wilson 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 2016-04-24 with Law categories.
With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
The Treatment And Taxation Of Foreign Investment Under International Law
DOWNLOAD
Author : Fiona Beveridge
language : en
Publisher: Juris Publishing, Inc.
Release Date : 2000
The Treatment And Taxation Of Foreign Investment Under International Law written by Fiona Beveridge and has been published by Juris Publishing, Inc. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000 with Law categories.
This is an examination of issues concerning the treatment of foreign investment and the taxation of investors. It examines the challenges which globalization has thrown up for the international community from a legal perspective, contrasting recent developments with a traditional approach.
An Economic Analysis Of Bilateral Investment Treaties
DOWNLOAD
Author : Jan Peter Sasse
language : en
Publisher: Springer Science & Business Media
Release Date : 2011-03-02
An Economic Analysis Of Bilateral Investment Treaties written by Jan Peter Sasse 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 2011-03-02 with Business & Economics categories.
Bilateral Investment Treaties (BITs) are an important instrument for the protection of foreign direct investment (FDI). However, compared to international trade law, international investment law has so far received only little research attention from an economic point of view. By applying a law and economics approach, Jan Peter Sasse provides a systematic analysis of the way BITs function. He explains why BITs are more than just a signal, how they relate to institutional competition as well as to institutional quality and why transparency in international investment arbitration is hard to achieve and may even be detrimental.
Oecd Arbitration In Tax Treaty Law
DOWNLOAD
Author : Alicja Majdanska
language : en
Publisher: Linde Verlag GmbH
Release Date : 2018-09-14
Oecd Arbitration In Tax Treaty Law written by Alicja Majdanska 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 2018-09-14 with Law categories.
Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.