Taxation Of Cross Border Income
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Taxation Of Cross Border Partnerships
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Author : Jesper Barenfeld
language : en
Publisher: IBFD
Release Date : 2005
Taxation Of Cross Border Partnerships written by Jesper Barenfeld 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 Double taxation categories.
Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."
Taxation Of Cross Border Income
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Author : Klaus Vogel
language : en
Publisher: Springer
Release Date : 1994-01-11
Taxation Of Cross Border Income written by Klaus Vogel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1994-01-11 with Business & Economics categories.
This study discusses the issues involved in making an informed choice between the source principle and the domicile principle as the basis for allocating the corporate profits base.
International Taxation Of Cross Border Leasing Income
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Author : Amar Mehta
language : en
Publisher: IBFD
Release Date : 2005
International Taxation Of Cross Border Leasing Income written by Amar Mehta 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 Corporations, Foreign categories.
This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.
Taxation Of Cross Border Portfolio Investment Mutual Funds And Possible Tax Distortions
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1999-05-04
Taxation Of Cross Border Portfolio Investment Mutual Funds And Possible Tax Distortions written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999-05-04 with categories.
This book analyses the taxation of cross-border portfolio investments by means of collective investment institutions. Possible tax distortions specific to the area of collective investment institutions are identified for a representative group of OECD countries.
Taxation Of Income From Domestic And Cross Border Collective Investment
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Author : Andreas Oestreicher
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-07-30
Taxation Of Income From Domestic And Cross Border Collective Investment written by Andreas Oestreicher 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 2013-07-30 with Law categories.
The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.
Characterisation And Taxation Of Cross Border Pipelines
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Author : Knut Olsen
language : en
Publisher: IBFD
Release Date : 2012
Characterisation And Taxation Of Cross Border Pipelines written by Knut Olsen 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 Double taxation categories.
Characterisation and Taxation of Cross-Border Pipelines provides a comprehensive analysis of the issues related to the taxation of cross-border pipelines. It offers solutions to the various tax issues that a cross-border pipeline might raise. The book concludes by recommending changes to the OECD Model Tax Treaty and its Commentaries to reduce uncertainty, avoid double taxation or less than a single taxation, and establish a more common international approach for the characterisation and taxation of cross-border pipelines and their allocation."--Publisher description.
Taxation Of Cross Border Portfolio Investment
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Author :
language : en
Publisher: Org. for Economic Cooperation & Development
Release Date : 1999
Taxation Of Cross Border Portfolio Investment written by and has been published by Org. for Economic Cooperation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999 with Business & Economics categories.
The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institution
International And Cross Border Taxation In New Zealand
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Author : Craig Macfarlane Elliffe
language : en
Publisher:
Release Date : 2015
International And Cross Border Taxation In New Zealand written by Craig Macfarlane Elliffe and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with Double taxation categories.
International Tax Cooperation
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Author : Luzius U. Cavelti
language : en
Publisher: Stämpfli Verlag
Release Date : 2016-10-27
International Tax Cooperation written by Luzius U. Cavelti and has been published by Stämpfli Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-10-27 with Law categories.
Why is international cooperation on taxation so difficult to achieve? The problems in international taxation arise from a sovereignty conflict between the country in which the income originates (source country) and the country in which the recipient of the income resides (residence country). This book explores the equally valid sovereign tax claims of source and of residence countries and highlights the incompatibility of these concurrent tax claims. The resulting incoherence between source and residence countries distorts taxation of cross-border income to a point where it not only creates discriminations but challenges the fundamental principles of international taxation in itself. This is an essential dilemma of international tax policy. And yet, given the profound role the power to tax plays in exercising sovereignty, are governments able, or even willing, to eliminate this essential dilemma?
Taxation Of Foreign Business Income Within The European Internal Market
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Author : Jérôme Monsenego
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Foreign Business Income Within The European Internal Market written by Jérôme Monsenego 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 Business enterprises, Foreign categories.
The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market.