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Special Features of the UN Model Convention
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amendi...
The New Italian Republic
The New Italian Republic charts the breakdown of the old party system and examines the changed political climate that has allowed Berlusconi to rise as Italy's new master and subsequently precipitated his rapid fall from power.
Taxation and the Financial Crisis
This book examines how tax policies contributed to the financial crisis; whether taxation can play a role in the reform efforts to establish a sounder and safer financial system; and the pros and cons of various tax initiatives.
Taxation in a Global Digital Economy
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Sustainability Engineering
Sustainability Engineering: Challenges, Technologies, and Applications focuses on emerging topics within sustainability science and engineering, including the circular economy, advanced recycling technologies, decarbonization, renewable energy, and waste valorization. Readers will learn the trends driving today’s sustainability research and innovation as well as the latest in sustainable process technologies. This book: Addresses emerging sustainability development challenges, progress, and disruptive technologies Discusses biological sustainability, recycling technologies, and sustainable process design and manufacture Features a comprehensive view from renowned experts who are leaders in their respective research areas This work is aimed at an interdisciplinary audience of engineers and scientists working on solutions to advance the development and application of sustainable technologies, including – but not limited to – chemical and environmental engineers.
Deconstruct to reconstruct
Deconstruct to reconstruct seeks to use a modern benefit principle theory that will allow tax authorities to tax companies in the digital economy, assuring they pay taxes in the countries in which they operate. The emergence of a new business models such as app stores, online advertising, cloud computing, participative network platforms, high-speed trading, and online payment services has reshaped the global economy and made it difficult for tax authorities to determine what and where to tax. Technologies in the new digital economy make it possible for companies to operate in countries without being physically present. While companies such as Netflix, Google, and AirBnB provide services and ...
The Challenge of the Digital Economy
This volume presents contributions that analyse the extraordinary impact of digital technology on business, services, and the production of value in many sectors of the economy. At the heart of this book is the fact that the entire digital economy is now worth almost 6% of global GDP, and it continues to grow at an unprecedented rate. The volume covers the general debate on taxation and the digital economy with the chapters by Russo, Makiyama and Boccia, before completing the analysis with discussion of three national case studies covering the U.S. (Pagano), U.K. (Leonardi) and Italy (Boccia and Leonardi). Contributors are leading experts in the fields of taxation and the digital economy and contextualise the key issues surrounding the digitalisation of the economy from an international perspective.
Locke and Biblical Hermeneutics
The volume presents illuminating research carried out by international scholars of Locke and the early modern period. The essays address the theoretical and historical contexts of Locke’s analytical methodology and come together in a multidisciplinary approach that sets biblical hermeneutics in relation to his philosophical, historical, and political thought, and to the philological and doctrinal culture of his time. The contextualization of Locke’s biblical hermeneutics within the contemporary reading of the Bible contributes to the analysis of the figure of Christ and the role of Paul’s theology in political and religious thought from the seventeenth century to the Enlightenment. The volume sheds light on how Locke was appreciated by his contemporaries as a biblical interpreter and exegete. It also offers a reconsideration that overarches interpretations confined within specific disciplinary ambits to address Locke’s thought in a global historic context.
Limiting Base Erosion
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...
Justice, Equality and Tax Law
An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repe...
