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Multilateral Cooperation in Tax Law
An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bri...
International Tax Planning and Prevention of Abuse
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Taxation of International Performing Artistes
The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.
Subsequent Agreements and Subsequent Practice in Domestic Courts
The book analyses how subsequent agreements and subsequent practice as defined in articles 31 and 32 of the 1969 Vienna Convention on the Law of Treaties have been applied in interpretative reality. Based on the jurisprudence of domestic courts, it elucidates the distribution of power between the parties to a treaty and other actors. To start with, the book traces the origins of subsequent agreements and subsequent practice and places them in their broader legal context. Next, it explores the legal status and effects of subsequent agreements and subsequent practice, explains why such agreements are only rarely used, and defines the relevance of non-party practice in the interpretative process. In closing, it critically examines how domestic courts have approached the normative heart of subsequent practice, i.e. the notion of ‘agreement’. Thus, this book ultimately challenges the traditional assumption that the parties are the joint masters of the treaty.
Tax Planning with Holding Companies - Repatriation of US Profits from Europe
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Towards a Homogeneous EC Direct Tax Law
Issues in 27 member states that might have an impact on their own cases. A new way of thinking is necessary in order to achieve a homogeneous application of non-harmonized community law dealing with direct taxation
Fundamental Issues and Practical Problems in Tax Treaty Interpretation
This volume deals in Part I with general principles of tax treaty interpretation, including many general issues of international law and especially treaty law. Part II is dedicated to specific tax treaty provisions that trigger particularly interesting interpretation questions. Part III is concerned with situations in which states disagree on the interpretation of tax treaties.
The Political Economy of International Tax Governance
Covering the period from the 1920s, when international tax policy was solely about avoiding double taxation, to the present era of international tax competition, Rixen investigates the fate of 'the power to tax' in an era of globalization, illustrating that tax sovereignty is both shaped and constrained by an international tax regime.
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...
