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Limiting Base Erosion
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to...
Special Features of the UN Model Convention
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amendi...
The DEMPE Concept and Intangibles
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, t...
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 Walls Have Ears
A history of the elaborate and brilliantly sustained World War II intelligence operation by which Hitler's generals were tricked into giving away vital Nazi secrets At the outbreak of World War II, MI6 spymaster Thomas Kendrick arrived at the Tower of London to set up a top secret operation: German prisoners' cells were to be bugged and listeners installed behind the walls to record and transcribe their private conversations. This mission proved so effective that it would go on to be set up at three further sites--and provide the Allies with crucial insight into new technology being developed by the Nazis. In this astonishing history, Helen Fry uncovers the inner workings of the bugging operation. On arrival at stately-homes-turned-prisons like Trent Park, high-ranking German generals and commanders were given a "phony" interrogation, then treated as "guests," wined and dined at exclusive clubs, and encouraged to talk. And so it was that the Allies got access to some of Hitler's most closely guarded secrets--and from those most entrusted to protect them.
The Organ and Its Music in German-Jewish Culture
The Organ and Its Music in German-Jewish Culture examines the powerful presence of the organ in synagogue music and in the general musical life of German-speaking Jewish communities in the 19th and 20th centuries. It explores the development of a new organ music repertoire as a paradigm for the changing identity of modern Jewry.
