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Exchange of Information in the EU
This timely book provides a holistic analysis of the exchange of information procedures for tax purposes within the EU from an administrative law and tax law perspective. It explores how procedural and substantive taxpayers’ rights are affected by exchange of information processes, and rigorously examines the effectiveness of the current legal framework.
The Attribution of Profits to Permanent Establishments
"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016
European Tax Law, Volume 1
Ben Terra (1946–2019) was professor of tax law at the universities of Amsterdam (UvA), the Netherlands, and Lund, Sweden. Peter Wattel is Advocate General in the Supreme Court of the Netherlands, State Councillor extraordinary in the Netherlands, Council of State and professor of EU tax law at the Amsterdam Centre for Tax Law (ACTL), University of Amsterdam. Sjoerd Douma is professor at the ACTL, Director of the Adv LLM programme in International Tax Law at Amsterdam Law School, and partner at Lubbers, Boer & Douma in The Hague. Otto Marres is professor at the ACTL, and tax lawyer at Meijburg & Co., Amsterdam. Hein Vermeulen is Director of PwC’s EU Direct Tax Group, Amsterdam. Dennis Web...
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...
Judicial Interpretation of Tax Treaties
Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
Criminal Justice and Taxation
A topical and lively discussion of how the criminal justice system attempts to ensure compliance with tax responsibility, discussing the development of tax evasion offences and the relationship between evasion and evidential rules, prosecution structures, and alternatives to prosecution.
Fiscal State Aid Law and Harmful Tax Competition in the European Union
The intersection between fiscal state aid and taxation has become more topical than ever. Mounting financial crises have left EU Member States scrambling to increase their tax revenue, balance their budgets, and attract capital. Taking advantage of these trends, multinational enterprises have lobbied for favourable tax arrangements, raising questions about the breadth of control the Commission can and should practise. To address egregious instances of favourable taxation, the Commission has tried to simultaneously use soft law and deploy Treaty rules on state aid. Fiscal State Aid Law and Harmful Tax Competition in the EU examines the use of state aid rules against national tax measures. Kyr...
2011
Particularly in the humanities and social sciences, festschrifts are a popular forum for discussion. The IJBF provides quick and easy general access to these important resources for scholars and students. The festschrifts are located in state and regional libraries and their bibliographic details are recorded. Since 1983, more than 639,000 articles from more than 29,500 festschrifts, published between 1977 and 2010, have been catalogued.
Co-operative Compliance and the OECD’s International Compliance Assurance Programme
Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the International Compliance Assurance Programme (ICAP), which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing dev...
Convenios fiscales internacionales y fiscalidad de la Unión Europea 2008
Especializada en el análisis de la normativa internacional tributaria que regula la doble imposición, el fraude de ley y la evasión fiscal de las rentas generadas por los sujetos pasivos no residentes en los estados donde éstas se producen. Ofrece un pormenorizado estudio de la legislación de la Unión Europea sobre imposición directa. NOVEDADES DE LA EDICIÓN 2008 Actualizado con todas las novedades que se han producido en esta materia. Esta edición recoge numerosas novedades en su contenido, procedentes tanto de diferentes fuentes jurídicas como de los criterios y conclusiones más recientes emanados de los foros internacionales acerca de los diferentes aspectos analizados en la ob...
