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Double non-taxation and the use of hybrid entities
The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific ta...
Transfer Pricing and the Arm's Length Principle in International Tax Law
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 f...
Tax Law Design and Drafting, Volume 1
Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States
"With particular reference to the Netherlands and the United States."--T.p.
Taxation of Derivatives and Cryptoassets
Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comm...
Coronavirus Disease (COVID-19): Pathophysiology, Epidemiology, Clinical Management and Public Health Response
Volume I.A An outbreak of a respiratory disease first reported in Wuhan, China in December 2019 and the causative agent was discovered in January 2020 to be a novel betacoronovirus of the same subgenus as SARS-CoV and named severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). Coronavirus disease 2019 (COVID-19) has rapidly disseminated worldwide, with clinical manifestations ranging from mild respiratory symptoms to severe pneumonia and a fatality rate estimated around 2%. Person to person transmission is occurring both in the community and healthcare settings. The World Health Organization (WHO) has recently declared the COVID-19 epidemic a public health emergency of international ...
Viruses and Reproductive Injustice
Brazil's Zika outbreak revealed extreme health disparities and reproductive injustice across racial and socioeconomic lines. Brazil's 2015 Zika outbreak led to severe illnesses for many and the birth of several thousands of children with severe brain damage. Even though mosquito-borne diseases such as the Zika virus affect people across society, these children were born almost exclusively to poor, and usually non-white, women. In Viruses and Reproductive Injustice, Ilana Löwy explores the complicated health disparities and reproductive injustice that led to these cases of congenital Zika syndrome. Löwy examines the history of the outbreak in Brazil and connects it to broader questions conc...
Transmission and Infection of Arboviruses
Worldwide, the most important arboviruses are chikungunya, dengue, Japanese encephalitis, Mayaro, West Nile, Zika, and Ross River viruses. A significant public health threat is posed by these viruses around the world, which threaten more than 3.6 billion people. In recent decades, scientists have revealed many issues with arboviruses and established approaches, allowing us to fight the diseases more effectively. However, old and new problems continue to haunt us, motivating us to develop new approaches to fight these diseases. A growing number of arboviruses have been detected in different regions of the world, emphasizing the need to better understand how these viruses are transmitted and infect.
Multilateral Tax Treaties
The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
The Fungal Cell Wall
This eBook is a collection of articles from a Frontiers Research Topic. Frontiers Research Topics are very popular trademarks of the Frontiers Journals Series: they are collections of at least ten articles, all centered on a particular subject. With their unique mix of varied contributions from Original Research to Review Articles, Frontiers Research Topics unify the most influential researchers, the latest key findings and historical advances in a hot research area! Find out more on how to host your own Frontiers Research Topic or contribute to one as an author by contacting the Frontiers Editorial Office: frontiersin.org/about/contact.
