The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law
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The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law
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Author : Valentin Bendlinger
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-10-17
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law written by Valentin Bendlinger 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 2023-10-17 with Law categories.
Rarely in the history of international tax law have there been so many evolutions in such a short space of time: In a dizzying array of reports, work programmes, consultations and announcements, the OECD, with the active support of the EU, has created a framework for a global minimum tax (Pillar Two or GloBE). In the meanwhile, jurisdictions are faced with the practical difficulties of incorporating an incredibly complex set of rules into their domestic legal systems. This book aims to shed light on the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and aims to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties and the EU’s recently adopted GloBE-Directive. The author not only analyses Pillar Two from a technical and a policy perspective but also provides for a comprehensive examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also includes practical examples and illustrates solutions to numerous technical and policy issues of Pillar Two. Among the seminal matters covered are the following: History and Background of the global minimum tax discussion. Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR. Tax policy implications and deficiencies of the final design of Pillar Two. The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties. The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive. The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms. Detailed comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive elucidate common points and deviations. In addition to comprehensive technical considerations, the book also provides a comprehensive tax policy perspective on the global minimum tax. For its unparalleled clarification of the issues alone, this book will prove invaluable to practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two. ‘Valentin Bendlinger’s book is an outstandingly remarkable work on a highly complex topic. The structure, clarity of thinking, and legal argumentation are excellent, and the legal and policy results throughout are profoundly argued. The book successfully ties together broad concepts of international and European (tax) law with highly complex and novel issues of the taxation of multinational enterprises. It should be highlighted that Valentin Bendlinger succeeded in leading the reader from the history and policy through a “jungle” of unprecedented rules to overarching fundamental issues of how the new taxation framework is to be placed in the international and European legal order.’ – Prof. DDr Georg Kofler, LLM (NYU), Vienna University of Economics and Business.
The Oecd S Global Minimum Tax And Its Implementation In The Eu
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Author : Valentin Bendlinger
language : en
Publisher:
Release Date : 2023
The Oecd S Global Minimum Tax And Its Implementation In The Eu written by Valentin Bendlinger and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023 with categories.
The Pillar Two Global Minimum Tax
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Author : Werner Haslehner
language : en
Publisher:
Release Date : 2024-08-28
The Pillar Two Global Minimum Tax written by Werner Haslehner and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-08-28 with Law categories.
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules. Key Features: Exploration of the Pillar 2 proposal's formative development Detailed discussion of key concepts such as process legitimacy Examination of the Pillar 2 objectives and the reasons which led to its adoption Assessment of the interaction between the GloBE rules and national law, European law and existing bilateral tax treaties Consideration of the impact of the new regime on multinational businesses and the future interaction of states through tax competition Step-by-step analysis of the complex set of GloBE model rules that have been put in place to make the minimum taxation regime effective This authoritative book is an essential resource for legal practitioners practising in tax law, fiscal policy and commercial law. The applied nature of the text is also of great benefit to policymakers working in the taxation sphere. Scholars and students of international taxation will similarly find this to be a useful reference.
Departures From The Oecd Model And Commentaries
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Author : Guglielmo Maisto
language : en
Publisher:
Release Date : 2014
Departures From The Oecd Model And Commentaries written by Guglielmo Maisto and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Double taxation categories.
"Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions including Australia, Austria, Belgium, China, Germany, Italy, the Netherlands, Spain and the United States. This book is essential reading for all those dealing with tax treaty issues and EU tax law."--Extracted from publisher website on May 19, 2015.
Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-03-27
Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition 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 2017-03-27 with categories.
This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
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.
Pillar Two Of The Inclusive Framework On Beps
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Author : Carlo Garbarino
language : en
Publisher:
Release Date : 2024-09-28
Pillar Two Of The Inclusive Framework On Beps written by Carlo Garbarino and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-09-28 with Law categories.
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems. Key Features: Exploration of the scope of the GloBE Rules Accessible explanations of technical jargon accompanied by examples Focus on key concepts of GloBE income or loss and adjusted covered taxes Concise descriptions of each area of OECD policies on the global minimum tax Examination of domestic qualified minimum taxes that align with OECD standards Analysis of tax neutrality and distribution regimes This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book's expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.
Harmful Tax Competition An Emerging Global Issue
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1998-05-19
Harmful Tax Competition An Emerging Global Issue 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 1998-05-19 with categories.
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Global Minimum Taxation
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Author :
language : en
Publisher:
Release Date : 2021
Global Minimum Taxation written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021 with categories.
Tax Challenges Arising From Digitalisation Interim Report 2018
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Author : Collectif
language : en
Publisher: OECD
Release Date : 2018-05-29
Tax Challenges Arising From Digitalisation Interim Report 2018 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 2018-05-29 with Business & Economics categories.
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.