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From Marks & Spencer to X Holding
The book deals with European law aspects of two European Court of Justice cases concerning cross-border tax relief claims and the decisions which have been criticized for lack of clarity and for breach of the freedom of establishment (Article 49 TFEU). The papers collected in the book cover the following issues: the underlying tax obstacles which exist for companies operating in more than one Member State; potential for tax avoidance; prevention of double use of losses (the 'no possibilities' test); disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty; the concept of 'balanced allocation of taxing powers'; meaning of 'final losses'; the 'Bosal fix'; cash-flow disadvantages of having to carry losses forward; deduction of currency losses; deduction-and-recapture rules; and VAT grouping.
The 2010 OECD Updates
Virtually all international taxation provisions ultimately stem from two fundamental sources, both originating at the OECD: The Model Tax Convention (on which more than 3,000 bilateral tax treaties are based), and the Transfer Pricing Guidelines. During 2010, major revisions were made to both. This unique book provides an expert analysis of current, important topics in international taxation and transfer pricing. As such, it is a welcome and valuable resource for tax lawyers and consultants, corporate tax advisers, government officials and others involved in the international tax law market, as well as for academics and researchers in the field.
Tax Treatment of Interest for Corporations
The tax treatment of interest for corporations continues to engage both tax academics and tax practitioners. In 'Tax Treatment of Interest for Corporations' various aspects of this matter (interest deduction limitations, discriminatory treatment of equity versus debt, preferential tax regimes on group interest income and withholding tax on interest) are dealt with from different perspectives, including economics, tax policy, comparative law, and EU and international law.
Dark Desire
“The Queen of paranormal romance.” —USA Today #1 New York Times bestselling author Christine Feehan has enchanted legions of paranormal romance fans with her sensation series featuring sexy immortal Carpathian heroes—a remarkable breed of vampire. In this stunning new edition of Dark Desire, a beautiful doctor is perilously drawn to the far Carpathian Mountains by a mysterious stranger who needs her medical expertise. Despite the danger, she cannot deny her deep connection to this mystery man—or he, his raging need for her. Discover the breathtaking power of supernatural love in this darkly sensuous classic from Christine Feehan.
Descriptive Translation Studies and Beyond
A replacement of the author's well-known book on Translation Theory, In Search of a Theory of Translation (1980), this book makes a case for Descriptive Translation Studies as a scholarly activity as well as a branch of the discipline, having immediate consequences for issues of both a theoretical and applied nature. Methodological discussions are complemented by an assortment of case studies of various scopes and levels, with emphasis on the need to contextualize whatever one sets out to focus on.Part One deals with the position of descriptive studies within TS and justifies the author's choice to devote a whole book to the subject. Part Two gives a detailed rationale for descriptive studie...
