Taxation Of Cross Border Dividends Paid To Individuals From An Eu Perspective
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Taxation Of Cross Border Dividends Paid To Individuals From An Eu Perspective
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Author : Erwin Nijkeuter
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-08-01
Taxation Of Cross Border Dividends Paid To Individuals From An Eu Perspective written by Erwin Nijkeuter 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 2012-08-01 with Law categories.
This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
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.
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation 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 dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Withholding Taxation In The Eu
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Author : Florian Haase
language : en
Publisher: Edward Elgar Publishing
Release Date : 2023-12-11
Withholding Taxation In The Eu written by Florian Haase 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 2023-12-11 with Law categories.
Florian Haase presents a comprehensive overview of the general mechanisms by which taxation is withheld in Europe and explores their practical implications. He expertly navigates the complexities of international tax law and provides a rigorous examination of the challenges currently facing this area of legislation, including tax evasion and avoidance, double taxation, and tax treaties.
European Union Corporate Tax Law
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Author : Christiana H. J. I. Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2021-06-17
European Union Corporate Tax Law written by Christiana H. J. I. Panayi 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 2021-06-17 with Law categories.
How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies, and permanent establishments. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.
The External Tax Strategy Of The Eu In A Post Beps Environment
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Author : Adolfo J. Martín Jiménez
language : en
Publisher:
Release Date : 2019
The External Tax Strategy Of The Eu In A Post Beps Environment written by Adolfo J. Martín Jiménez and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with categories.
Tax Co Ordination In The European Union
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Author : Ben Patterson
language : en
Publisher: Virago Press
Release Date : 2001
Tax Co Ordination In The European Union written by Ben Patterson and has been published by Virago Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001 with MacDonnell Ranges (N.T.) categories.
This is an updated study of a 1998 publication, "Tax competition in the European Union". The introduction covers the recent history of tax policy within the EU, and examines the current situation in corporate taxation, taxation of savings, taxation of labour, and indirect taxation (VAT and excise duty). A comparative analysis provides a detailed survey of how direct taxes - corporate and personal - are levied within the EU. The final section discusses the main issues in the current debate on the alternative approaches of competition and co-operation in the taxation field.
Research Handbook On European Union Taxation Law
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Author : Christiana HJI Panayi
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-01-31
Research Handbook On European Union Taxation Law written by Christiana HJI Panayi 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 2020-01-31 with Law categories.
Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.
European Union Corporate Tax Law
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Author : Christiana HJI Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2013-05-09
European Union Corporate Tax Law written by Christiana HJI Panayi 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 2013-05-09 with Law categories.
How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.
The Nordic Multilateral Tax Treaty As A Model For A Multilateral Eu Tax Treaty
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Author : Marjaana Helminen
language : en
Publisher:
Release Date : 2013
The Nordic Multilateral Tax Treaty As A Model For A Multilateral Eu Tax Treaty written by Marjaana Helminen 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.
Switzerland In International Tax Law
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Author : Xavier Oberson
language : en
Publisher: IBFD
Release Date : 2011
Switzerland In International Tax Law written by Xavier Oberson 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 Double taxation categories.
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).