The Pillar Two Global Minimum Tax
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The Pillar Two Global Minimum Tax
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Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-08-06
The Pillar Two Global Minimum Tax written by Werner Haslehner 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 2024-08-06 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.
Taxing Profit In A Global Economy
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Author : Michael P. Devereux
language : en
Publisher: Oxford University Press
Release Date : 2020-09-29
Taxing Profit In A Global Economy written by Michael P. Devereux 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 2020-09-29 with Business & Economics categories.
1:Introduction 2:Key issues in taxing profit 3:The current international tax system 4:Fundamental reform options 5:Basic choices in considering reform 6:Residual profit allocation by income 7:Destination-based cash flow taxation.
International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots
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Author : Sebastian Beer
language : en
Publisher: International Monetary Fund
Release Date : 2018-07-23
International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots written by Sebastian Beer and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-07-23 with Business & Economics categories.
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
The Global Minimum Tax Selected Issues On Pillar Two
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Author : Valentin Bendlinger
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-10-18
The Global Minimum Tax Selected Issues On Pillar Two written by Valentin Bendlinger 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 2024-10-18 with Law categories.
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation
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Author : Aqib Aslam
language : en
Publisher: International Monetary Fund
Release Date : 2021-06-08
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation written by Aqib Aslam and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-08 with Business & Economics categories.
This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.
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 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.
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Interim Report 2018 Inclusive Framework On Beps
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2018-03-16
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Interim Report 2018 Inclusive Framework On Beps 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 2018-03-16 with 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.
Pleural Diseases
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Author : Richard W. Light
language : en
Publisher: Lippincott Williams & Wilkins
Release Date : 2007
Pleural Diseases written by Richard W. Light and has been published by Lippincott Williams & Wilkins this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Medical categories.
Thoroughly updated for its Fifth Edition, Dr. Light's classic text provides a focused, single-authored perspective on the pathophysiology, clinical manifestations, diagnosis, and management of pleural diseases. This edition has three new chapters on physiological effects of a pneumothorax or pleural effusion, animal models in pleural investigation, and cytokines and the pleura. Other chapters present significant updates on use of thoracoscopy in diagnosis of pleural effusions and on new diagnostic tests for mesothelioma, parapneumonic effusion, and effusions due to congestive heart failure. Also included are discussions of recent advances in the therapy of malignant pleural effusions, mesothelioma, and parapneumonic effusions.
Imposing Standards
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Author : Martin Hearson
language : en
Publisher: Cornell University Press
Release Date : 2021-06-15
Imposing Standards written by Martin Hearson and has been published by Cornell University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-15 with Business & Economics categories.
In Imposing Standards, Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits on the ability of developing countries to tax businesses, denying the Global South access to much-needed revenue. The international rules that allow tax avoidance by multinational corporations have dominated political debate about international tax in the United States and Europe, especially since the global financial crisis of 2007–2008. Hearson asks how developing countries willingly gave up their right to tax foreign companies, charting their assimilation into an OECD-led regime from the days of early independence to the present day. Based on interviews with treaty negotiators, policymakers and lobbyists, as well as observation at intergovernmental meetings, archival research, and fieldwork in Africa and Asia, Imposing Standards shows that capacity constraints and imperfect negotiation strategies in developing countries were exploited by capital-exporting states, shielding multinationals from taxation and depriving nations in the Global South of revenue they both need and deserve. Thanks to generous funding from the Gates Foundation, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.