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Transfer Pricing and Dispute Resolution
This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational compani...
Private Client Tax
Private Client Tax is the essential reference guide for anyone concerned with cross border trust, estate and succession planning for wealthy international families.This includes not only family members themselves, but Private Banks, Family Offices and professionals serving this sector as accountants, tax advisers, lawyers, art and property advisors etc.Covering over 25 major jurisdictions worldwide this title offers you insight into the basic legal framework in each jurisdiction with commentary on topics on which anyone considering taking up residence in a new jurisdiction needs to focus.
Money and Morals Worldwide
Experts from the major world economies discuss problems and distortions in their financial systems, international implications of these distortions, and possible solutions. Areas addressed include: money laundering, corruption, the mafia, stock market manipulation, derivative products, pension funds, banking systems, currency, taxation, emerging markets. This is an annual volume from the Finance, Ethics, and Confidence research program created by the Caisse des Depots et Consignations and conducted by the Association d'economie financiere.
Concept and Implementation of CFC Legislation
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions ...
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.
CFC Legislation, Tax Treaties and EC Law
Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
IBSS: Economics: 1993 Vol 42
This bibliography lists the most important works published in economics in 1993. Renowned for its international coverage and rigorous selection procedures, the IBSS provides researchers and librarians with the most comprehensive and scholarly bibliographic service available in the social sciences. The IBSS is compiled by the British Library of Political and Economic Science at the London School of Economics, one of the world's leading social science institutions. Published annually, the IBSS is available in four subject areas: anthropology, economics, political science and sociology.
Introduction to Transfer Pricing
Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at p...
Global Forum on Transparency and Exchange of Information for Tax Purposes: Luxembourg 2019 (Second Round) Peer Review Report on the Exchange of Information on Request
This report contains the 2019 Peer Review Report on the Exchange of Information on Request of Luxembourg.
Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries
In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
