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Tax Implications of Brexit is an essential guide for anyone advising businesses trading in either the United Kingdom or the European Union post-Brexit. In two parts, this title provides an in-depth analysis of the tax ramifications of Brexit in both the United Kingdom and EU Member States, helping to identify immediate and future issues that could be faced post-Brexit, and how to mitigate any risks. Part One features two chapters on the tax implications of Brexit in the United Kingdom, as well as subject-specific chapters which deal with the impact of Brexit on VAT, custom duties and excises and State Aid legislation. Part Two is split into EU country chapters, dealing with the tax implicati...
A global comparison of the laws and regulations that govern investment funds is an invaluable tool to anyone involved in the business.
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...
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Tax Implications of Brexit is an essential guide for anyone advising businesses trading in either the United Kingdom or the European Union post-Brexit. In two parts, this title provides an in-depth analysis of the tax ramifications of Brexit in both the United Kingdom and EU Member States, helping to identify immediate and future issues that could be faced post-Brexit, and how to mitigate any risks. Part One features subject-specific chapters which deal with the UK statutory regime after 2020 as well as the impact of Brexit on VAT, customs and excise duties and State Aid legislation. Part Two is split into country chapters dealing with the tax implications in the single jurisdictions (the Un...
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.
The growing interest in investment in Latin America - particularly in commodities production and real estate development - has increased the use of trusts as investment vehicles throughout Latin America. Written for the English-speaking practitioner, the book covers Argentina, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Honduras, México, Panamá, Paraguay, Perú, Uruguay and Venezuela and provides a practical, clear, and thorough explanation of trusts as legal vehicles for investment in Latin American countries. Trusts in Latin America provides a comprehensive, comparative review of statutes, case law, and examples of trusts in Latin America, and also highlights differences between these countries and common-law systems.
It is now easier than ever for ultra-high-net-worth individuals to relocate and select a country as their residence, and in light of a variety of circumstances, including political instability and the proliferation of special tax regimes across more countries designed to attract the wealthy, this is a continually increasing trend. However these individuals must consider a wide range of factors when deciding whether to relocate internationally, and so advisers need to take a holistic approach. This title, featuring contributions by leading private client advisers from 16 key jurisdictions worldwide, provides readers with expert guidance on the tax and legal aspects of inbound and outbound transfer of residence of ultra-high-net-worth individuals. Chapters cover the relevant law in their respective jurisdictions relating to: immigration; tax; succession; and family. It also considers the application of tax treaties to beneficial tax regimes, and the relocation of works of art, as well as other key topics. This book will be an invaluable tool for lawyers, tax advisers, bankers and all professionals who assist ultra-high-net-worth individuals.