Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties
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Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties
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Author : International Bureau of Fiscal Documentation
language : en
Publisher:
Release Date : 2013
Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties written by International Bureau of Fiscal Documentation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Capital gains tax categories.
"Taxation of Companies on Capital Gains on Shares under Domestic Law, EU Law and Tax Treaties, comprising the proceedings and working documents of a seminar held in Milan on 26 November 2012, is a detailed and comprehensive study on the taxation of capital gains on shares derived by companies."--Extracted from publisher website on March 25, 2014.
Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties
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Author :
language : en
Publisher:
Release Date : 2013
Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with categories.
This book is a comprehensive study on the taxation of capital gains on shares derived by companies. The book begins by discussing the trends in the taxation of capital gains on shares under domestic law, taking into account the input from various national reports. It then considers the taxation of capital gains on shares in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of capital gains on shares and the possible impact of the EU income tax directives are examined. Next, the book discusses the taxation of capital gains on shares under tax treaties. The focus initially is on the notion of "capital gains on shares" in the OECD Model Convention and the qualification conflicts possibly arising in this respect. In addition, attention is also devoted to tax treaty aspects of company reorganizations that could trigger taxation of capital gains on shares and to tax treaty provisions regarding shares attributable to permanent establishments and non-discrimination. Finally, the application of domestic and agreement-based anti-abuse rules to transfers of shares is thoroughly analysed, with an eye also on recent rules and doctrines aimed at taxing indirect transfers. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in North America, selected European jurisdictions, Australia, China and India.
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Intercompany Dividends Under Tax Treaties And Eu 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 2012 with Corporations categories.
"Taxation of Intercompany Dividends under Tax Treaties and EU Law, comprising the proceedings and working documents of an annual seminar held in Milan on 1 October 2011, is a detailed and comprehensive study on the taxation of cross-border dividend distributions."--Extracted from publisher website on March 27, 2015
Taxation Of Investment Funds In The European Union
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Author : Tomi Viitala
language : en
Publisher: IBFD
Release Date : 2005
Taxation Of Investment Funds In The European Union written by Tomi Viitala and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Capital gains tax categories.
The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Investment Fund Taxation
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Author : Werner Haslehner
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-04-24
Investment Fund Taxation written by Werner Haslehner 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 2017-04-24 with Law categories.
The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.
International And Ec Tax Aspects Of Groups And Companies
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2008
International And Ec Tax Aspects Of Groups And Companies 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 2008 with Corporations categories.
Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.
Comparative Law Yearbook Of International Business Volume 43
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Author : Christian Campbell
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-11-11
Comparative Law Yearbook Of International Business Volume 43 written by Christian Campbell 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 2021-11-11 with Law categories.
The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.
Tax Treaty Case Law Around The Globe 2019
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2020-07-22
Tax Treaty Case Law Around The Globe 2019 written by Michael Lang 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 2020-07-22 with Law categories.
A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
International Taxation Of Manufacturing And Distribution
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Author : John Abrahamson
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-02-18
International Taxation Of Manufacturing And Distribution written by John Abrahamson 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 2016-02-18 with Law categories.
The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes
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Author : Bruno da Silva
language : en
Publisher: Eucotax Series on European Tax
Release Date : 2016
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes written by Bruno da Silva and has been published by Eucotax Series on European Tax this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016 with Law categories.
"The existence of tax groups is motivated by the principle of neutrality in the taxation of corporate activities: tax systems should tax the income in the same way irrespective of the organic structure adopted for that purpose. This means that a tax system should not lead to distortions only because such activity was not performed by a single company but rather through a group of companies. Tax group regimes exist in many Member States although most of them are applicable only to domestic companies. Therefore, the possibilities of cross-border group taxation are still very limited at the EU Level. The limitation of tax group benefits to domestic situations and the difference in treatment between domestic and cross-border constitute situations which may affect neutrality and therefore, create obstacles as to an efficient allocation of resources. This thesis analyses how tax treaties and EU law may contribute to remove existing obstacles to group taxation regimes, meaning the differences created by national laws between domestic and cross-border groups. This assessment is fundamentally based on the interpretation of the non-discrimination provisions in tax treaties as well as the EU fundamental freedoms. It also considers the possibility of developing new approaches based on the interpretation of tax treaties and EU law such as to extend the application of group taxation regimes to cross-border situations."--Samenvatting auteur.