Advanced Introduction to International Tax Law

  • Filename: advanced-introduction-to-international-tax-law.
  • ISBN: 9781781952320
  • Release Date: 2015-02-27
  • Number of pages: 136
  • Author: Reuven S. Avi-Yonah
  • Publisher: Edward Elgar Publishing

Advanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax. Systems of taxation deviate between jurisdictio

Switzerland in International Tax Law

  • Filename: switzerland-in-international-tax-law.
  • ISBN: 9789087220983
  • Release Date: 2011
  • Number of pages: 432
  • Author: Xavier Oberson
  • Publisher: IBFD

"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).

Transfer Pricing and the Arm s Length Principle in International Tax Law

  • Filename: transfer-pricing-and-the-arm-s-length-principle-in-international-tax-law.
  • ISBN: 9789041132703
  • Release Date: 2010
  • Number of pages: 880
  • Author: Jens Wittendorff
  • Publisher: Kluwer Law International

The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

International Tax Law

  • Filename: international-tax-law.
  • ISBN: 1785360213
  • Release Date: 2016
  • Number of pages: 1480
  • Author: Reuven Shlomo Avi-Yonah
  • Publisher:

In the last twenty years a critically important debate has dominated international tax scholarship: whether an international tax regime exists and if countries are constrained by it within their own tax legislation. This debate has had major implications on the current post-financial crisis efforts by governmental organizations, such as the G20 and OECD, in drafting multilateral international tax rules. This research review draws upon the most important papers published in the last two decades to comprehensively address the increasingly relevant issues of international tax law.

International Taxation in a Nutshell

  • Filename: international-taxation-in-a-nutshell.
  • ISBN: 031419424X
  • Release Date: 2009
  • Number of pages: 548
  • Author: Richard L. Doernberg
  • Publisher: West Academic

Offers a concise exposition of the United States tax laws involved in international business and investment transactions.

International Tax as International Law

  • Filename: international-tax-as-international-law.
  • ISBN: 9781139465830
  • Release Date: 2007-09-10
  • Number of pages:
  • Author: Reuven S. Avi-Yonah
  • Publisher: Cambridge University Press

This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.

International Applications of U S Income Tax Law

  • Filename: international-applications-of-u-s-income-tax-law.
  • ISBN: 9780471482819
  • Release Date: 2003-11-20
  • Number of pages: 400
  • Author: Ernest R. Larkins
  • Publisher: John Wiley & Sons

A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!

The International Tax Law Concept of Dividend

  • Filename: the-international-tax-law-concept-of-dividend.
  • ISBN: 9789041132062
  • Release Date: 2010
  • Number of pages: 281
  • Author: Marjaana Helminen
  • Publisher: Kluwer Law International

The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: and• Payments made under dividend-stripping arrangements. and• Fictitious profit distributions. and• Economic benefits in the context of transfer pricing. and• Returns on debt-equity hybrids. and• Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law. The approaches adopted in different statesand’ national tax law are covered by a more general analysis. The comprehensive coverage and practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Advanced Issues in International and European Tax Law

  • Filename: advanced-issues-in-international-and-european-tax-law.
  • ISBN: 9781849469548
  • Release Date: 2015-12-03
  • Number of pages: 384
  • Author: Christiana HJI Panayi
  • Publisher: Bloomsbury Publishing

This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world.

The Interface of International Trade Law and Taxation

  • Filename: the-interface-of-international-trade-law-and-taxation.
  • ISBN: 9789087221829
  • Release Date: 2013
  • Number of pages: 314
  • Author: Jennifer E. Farrell
  • Publisher: IBFD

This book explores the ill-defined and oft-underestimated relationship between the World Trade Organization (WTO) and taxation. By adopting a two-pronged approach, the relationship is examined in terms of the extent to which the WTO legal framework exerts influence upon domestic tax law and international tax policy, and whether it is appropriate for the WTO to play a regulatory role in the field of taxation. The book begins with an examination of the historical development of international trade law and international tax law, and demonstrates that these two separate areas of law are closely linked in terms of their underlying principles and historical evolution. The work then goes on to offer a doctrinal analysis of the tax content found in the WTO legal texts and highlights ambiguities therein.

International Tax Law

  • Filename: international-tax-law.
  • ISBN: 9789041123909
  • Release Date: 2006
  • Number of pages: 406
  • Author: Andrea Amatucci
  • Publisher: Kluwer Law International

A collection of eleven essays that offers an analysis of the fundamental theory of tax law, and of the prospects in future of tax legislative systems. The emphasis is on tax theory, jurisprudence, and legislative development in the member states of the European Union. This book is useful to practitioners and academics in tax law.

International Taxation of Permanent Establishments

  • Filename: international-taxation-of-permanent-establishments.
  • ISBN: 9781139500227
  • Release Date: 2011-09-15
  • Number of pages:
  • Author: Michael Kobetsky
  • Publisher: Cambridge University Press

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

Double Taxation Conventions and International Tax Law

  • Filename: double-taxation-conventions-and-international-tax-law.
  • ISBN: 0421493704
  • Release Date: 1994
  • Number of pages: 514
  • Author: Philip Baker
  • Publisher: Sweet & Maxwell Uk

Double taxation conventions are playing an increasingly major role in the tax world. The OECD Model Double Taxation Convention is used as the basis for most of the world's double taxation treaties. The UK has now almost 100 agreements with other countries and the vast majority of international trade and investment is now governed by such agreements rather than by general law.

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