Taxpayers In International Law
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Taxpayers In International Law
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Author : Juliane Kokott
language : en
Publisher: Bloomsbury Publishing
Release Date : 2022-03-24
Taxpayers In International Law written by Juliane Kokott and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-03-24 with Law categories.
This ground-breaking book brings clarity to the dynamically developing field of international tax law. It empowers individuals and corporate taxpayers to navigate their way around and helps tax authorities take taxpayers' rights into account from the beginning. The book is the result of several years of research conducted with the support of the International Law Association. Taxpayers in International Law puts taxpayers' rights on the global international tax agenda as the necessary counterweight and complement to Base Erosion and Profit Shifting (BEPS). Importantly, it pleads for a global minimum standard of legal protection of the fundamental rights of taxpayers and extracts the content of such rights from relevant constitutional principles of many countries around the world. The book is structured in 3 parts: Part I focusses on the legal sources and on the relations between taxation and international human rights law. Part II identifies general principles and specific taxpayers' rights, groups them into 3 categories (procedural, related to sanctions, and substantive), and analyses the different implications that arise in each of them. Part III features concrete proposals for establishing a global framework for the protection of taxpayers' rights, including guidelines for tax authorities. The book is a unique instrument for the daily work of practitioners and international tax scholars interested in securing the protection of taxpayer's fundamental rights, as well as for those involved in tax collection worldwide. Taxpayers can refer to the book to find out which rulings and concepts can help them enforce their rights; tax authorities and judges can use the book to verify which rights have to be respected.
Interpretation Of Tax Treaties Under International Law
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Author : F. A. Engelen
language : en
Publisher: IBFD
Release Date : 2004
Interpretation Of Tax Treaties Under International Law written by F. A. Engelen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with Double taxation categories.
This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
International Exchange Of Information And The Protection Of Taxpayers
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Author : A. C. M. Schenk-Geers
language : en
Publisher: Kluwer Law International
Release Date : 2009
International Exchange Of Information And The Protection Of Taxpayers written by A. C. M. Schenk-Geers and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Confidential communications categories.
This book focuses on the legal position of the taxpayer in the exchange of tax-related information between states. It begins with the legal-philosophical background of legal protection, which is followed by a description and analysis of the international legal framework for cross-border exchange of information. In the following chapters the attention is paid to the role of the OECD Model Tax Convention, OECD Agreement on Exchange of Information on Tax Matters, the Convention of Strasbourg, the European Directive 77/799 and the Council Regulation 1789/2003. Further, the author examines the interests of the taxpayers and gives outlines for a system of legal protection of taxpayers' right.
Advanced Introduction To International Tax Law
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Edward Elgar Publishing
Release Date : 2019
Advanced Introduction To International Tax Law written by Reuven S. Avi-Yonah 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 Double taxation categories.
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
International Law Of Taxation
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Author : Peter Hongler
language : en
Publisher: Oxford University Press
Release Date : 2021
International Law Of Taxation written by Peter Hongler 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 2021 with Law categories.
In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.
The Public International Law Of Taxation
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Author : Asif H. Qureshi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-22
The Public International Law Of Taxation written by Asif H. Qureshi 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 2019-05-22 with Law categories.
The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.
Protection Of Taxpayer S Rights
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Author : Włodzimierz Nykiel
language : en
Publisher:
Release Date : 2009-01
Protection Of Taxpayer S Rights written by Włodzimierz Nykiel and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009-01 with Law categories.
Taxpayers Rights
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Author : Duncan Bentley
language : en
Publisher:
Release Date : 1998
Taxpayers Rights written by Duncan Bentley and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998 with Tax administration and procedure categories.
International Law In Relation To Double Taxation Of Income
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Author : I. P. Gupta
language : en
Publisher:
Release Date : 2007
International Law In Relation To Double Taxation Of Income written by I. P. Gupta and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Double taxation categories.
The first part of the book contains a brief description, by way of preliminary information, of the nature and sources of international law (including international tax law), the interplay of customary and conventional international law with the municipal law, and the Vienna Convention on the law of treaties. Part II deals mainly with the subject of the impact of public and private international law on the legislative and enforcement jurisdictions of sovereign states; the jurisdictional immunities available under the international law; and the law of sea. Part III mainly deals with the nature and occurrence of double taxation; evolution of various methods for the purpose of avoidance of the cumulative burden on taxpayers.
International Tax Primer
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Author : Brian J. Arnold
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-03-09
International Tax Primer written by Brian J. Arnold 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 2023-03-09 with Law categories.
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition. Unquestionably, the most important development in international tax since the publication of the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition explores in detail both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. Also new to the fifth edition are sections dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: taxation of residents on foreign income and nonresidents on domestic income; mechanisms used to mitigate the risks to taxpayers of international double taxation; transfer pricing rules to prevent the avoidance of tax by multinational corporations; anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
