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EC Law Aspects of Hybrid Entities
This study discusses the impact of the EC Treaty on the recognition of entities in the internal market. The EC Treaty envisages the internal market as an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured in accordance with the provisions of the EC Treaty. One of the key questions discussed in this study is how this rationale reflects the relation between tax laws of Member States and, specifically, the relation between the application of autonomous classification methods by Member States and the free allocation of economic resources in the internal market. This study also contains an examination of how the different approaches to hybrid entities in tax treaties interfere with EC law. This part of the study contains an analysis of how the interrelation between domestic (tax) laws and the approach to classification conflicts under existing bilateral tax treaties relates to EC law.
Concept and Implementation of CFC Legislation
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions ...
The Effect of Treaties on Foreign Direct Investment
Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries
In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Transfer Pricing
This paper on transfer pricing is part of the "UNCTAD Series on issues in international investment agreements". It provides balanced analysis of issues that may arise in discussions about international investment agreements.
The Economist
None
Tax Incentives and Foreign Direct Investment
Foreign direct investment (FDI) is increasingly being recognized as an important factor in the economic development of countries. More and more countries are striving to create a favourable and enabling climate to attract FDI as a policy priority. This study contains a survey of tax incentive regimes in over 45 countries in the world.
Report
None
International Investment Agreements
This is part of a three-set volume bringing together the series of papers published by UNCTAD on key issues in international investment agreements. The Series seeks to help developing countries to participate as effectively as possible in international investment rule making at the bilateral, regional, plurilateral and multilateral levels. Addressed to Government officials, corporate executives, representatives of non-governmental organizations, officials of international agencies and researchers, the Series provides a balanced analysis of issues that may arise in discussions about, and negotiations of, international investment agreements.
