Taxing German Dutch Cross Border Activities

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Taxing German Dutch Cross Border Activities

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Author : Bert Alink
language : en
Publisher: Institut für Finanz- und Steuerrecht, Universität Osnabrück
Release Date : 2015-02-04

Taxing German Dutch Cross Border Activities written by Bert Alink and has been published by Institut für Finanz- und Steuerrecht, Universität Osnabrück this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-02-04 with Law categories.

Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.

Introduction To The Law Of Double Taxation Conventions

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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-04-01

Introduction To The Law Of Double Taxation Conventions 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 2021-04-01 with Law categories.

The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.

International Vat Gst Guidelines

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Author : Collectif
language : en
Publisher: OECD
Release Date : 2017-04-12

International Vat Gst Guidelines written by Collectif and has been published by OECD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-04-12 with Business & Economics categories.

Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) has become a major source of revenue for governments around the world. Some 165 countries operated a VAT at the time of the completion of the International VAT/GST Guidelines in 2016, more than twice as many as 25 years before. As VAT continued to spread across the world, international trade in goods and services has also expanded rapidly in an increasingly globalised economy. One consequence of these developments has been the greater interaction between VAT systems, along with growing risks of double taxation and unintended non-taxation in the absence of international VAT co-ordination. The International VAT/GST Guidelines now present a set of internationally agreed standards and recommended approaches to address the issues that arise from the uncoordinated application of national VAT systems in the context of international trade. They focus in particular on trade in services and intangibles, which poses increasingly important challenges for the design and operation of VAT systems worldwide. They notably include the recommended principles and mechanisms to address the challenges for the collection of VAT on cross-border sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project). These Guidelines were adopted as a Recommendation by the Council of the OECD in September 2016.

Addressing Base Erosion And Profit Shifting

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2013-02-12

Addressing Base Erosion And Profit Shifting 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 2013-02-12 with categories.

This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

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.

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-10

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017 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 2017-07-10 with categories.

This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Hybrid Entities In Tax Treaty Law

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Author : Sriram Govind
language : en
Publisher: Linde Verlag GmbH
Release Date : 2020-09-03

Hybrid Entities In Tax Treaty Law written by Sriram Govind 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 2020-09-03 with Law categories.

Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.

Model Tax Convention On Income And On Capital Condensed Version 2017

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-12-18

Model Tax Convention On Income And On Capital Condensed Version 2017 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 2017-12-18 with categories.

This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...

The Taxation Of Pensions

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Author : Robert Holzmann
language : en
Publisher: MIT Press
Release Date : 2018-08-07

The Taxation Of Pensions written by Robert Holzmann and has been published by MIT Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-08-07 with Business & Economics categories.

Theoretical and policy perspectives on the taxation of pension, viewed in an international context. Policy makers and academic researchers have been preoccupied in recent decades with the design of pension schemes and effective pension system reform. Relatively little attention has been given to the taxation of pensions and, more broadly, the provision of retirement income. In this book, experts from a range of countries explore the interconnection. Their contributions are especially timely, given recent demographic and political developments including population aging that lengthens the time between contribution payment and benefit receipt, the mobility of capital and labor brought about by globalization, and the complexity of pension taxation within and between countries. In shedding light on these issues, the chapters document the various forms of taxation of pension systems; use economic theory to explain both qualitative and quantitative observations; and consider whether the observed interaction of taxation and pensions is efficient. Theoretical overviews are followed by rigorous analyses of pension taxation in specific countries, including Denmark, Sweden, Portugal, Australia, Germany, the United Kingdom, and the United States. Contributors Torben M. Andersen, Spencer Bastani, Hazel Bateman, Sören Blomquist, Axel Börsch-Supan, Jorge Miguel Bravo, Gary Burtless, Rafal Chomik, Helmuth Cremer, Carl Emmerson, Csaba Feher, Bernd Genser, Robert Holzmann, Paul Johnson, Alain Jousten, Christian Keuschnigg, Eric Koepcke, George Kudrna, Jukka Lassila, Luca Micheletto, Pierre Pestieau, John Piggott, Christopher Quinn, Tarmo Valkonen, Alan Woodland

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.