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Business Operations in Argentina
... contains information enabling foreign businesses and their professional advisors to determine the best methods of conducting business operations in Argentina from both the tax and general legal points of view. It analyzes in detail the statutory and procedural framework of Argentine taxation as it applies to corporations and individuals. In addition to providing a detailed explanation of the Argentine system of income taxation, the Portfolio discusses the legal forms of business enterprises, licensing and franchising in Argentina, immigration regulations, labor relations, business financing, currency and exchange control, value added tax, and the personal assets tax, as well as the impact on the Argentine tax treatment of the tax treaties entered into by Argentina.
Tax Sovereignty in the BEPS Era
BEPS and the power to tax / Allison Christians -- Tax sovereignty and digital economy in post-BEPS times / Ramon Tomazela Santos & Sergio André Rocha -- Justification and implementation of the international allocation of taxing rights: can we take one thing at a time? / Luís Eduardo Schoueri & Ricardo André Galendi Júnior -- An essay on BEPS / Sovereignty / and Taxation / Yariv Brauner -- Evaluating BEPS / Reuven S. Avi-Yonah & Haiyan Xu -- Jurisdictional excesses in BEPS' times: national appropriation of an enhanced global tax basis / Guillermo O. Teijeiro -- Taxing the consumption of digital goods / Aleksandra Bal -- The birth of a new international tax framework and the role of developing countries / Natalia Quiñones -- The other side of BEPS: "imperial taxation" and "international tax imperialism" / Sergio André Rocha -- Country-by-country over-reporting? national sovereignty, international tax transparency, and the inclusive framework on BEPS / Romero J.S. Tavares -- How are we doing with BEPS recommendations in the EU? / Tomas Balco & Xeniya Yeroshenko -- U.S. tax sovereignty and the BEPS project / Tracy A. Kaye
Global Transfer Pricing Solutions
GLOBAL TRANSFER PRICING SOLUTIONS: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property. This report was prepared by members of major law and accounting firms and senior international transfer pricing professionals at the largest multinationals. It covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, and North America.
The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention
Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and othe...
A Multilateral Convention for Tax
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI...
Tax Sovereignty in the BEPS Era
The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors pro...
