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Tax Law Design and Drafting, Volume 2
A comprehensive guide to income tax legislation, this book is the second of two volumes dealing with tax legislation from a comparative law perspective. Distilled from the IMF Legal Department's extensive experience, the book covers a wide range of issues in both domestic and international taxation. It also includes the most extensive bibliography currently available of the national tax laws of IMF member countries.
Cooper, Krever & Vann's Income Taxation
Cooper, Krever & Vann's Income Taxation: Commentary and Materials, 6th Edition continues to focus on lasting skills for interpretation of this constantly evolving area of law. Distinctive commentary from leading tax academics and thought-provoking questions with a practical application combine to engage and educate readers in the subject. Instead of merely concentrating on the present state of the tax system, the book prepares readers to deal with future clients and taxation issues by imparting valuable tools such as the ability to: analyse rules and principles; apply relevant cases and other primary sources to a situation; manipulate and implement technical rules of legislation; consider taxation issues in terms of policy; and understand the dynamics of taxation disputes. Cooper, Krever & Vann's Income Taxation: Commentary and Materials, 6th Edition is the ideal work for readers who wish to attain high-level lasting knowledge of Australia's income tax system and gain the confidence to apply their knowledge in the future.
Cooper, Krever and Vann's Income Taxation
This edition continues to focus on lasting skills for interpretation of this constantly evolving area of law. Distinctive commentary from leading tax academics and thought-provoking questions with a practical application combine to engage and educate readers in the subject. Instead of merely concentrating on the present state of the tax system, the book prepares readers to deal with future clients and taxation issues by imparting valuable tools such as the ability to: analyse rules and principles; apply relevant cases and other primary sources to a situation; manipulate and implement technical rules of legislation; consider taxation issues in terms of policy; and understand the dynamics of taxation disputes.
International Taxation of Trust Income
This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
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.
Dispute Resolution Under Tax Treaties
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in dif...
Courts and Tax Treaty Law
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of th...
International and Comparative Taxation:Essays in Honour of Klaus Vogel
Compilation of the 16 English language contributions of "Staaten und Steuern (States and Taxes)", the original festschrift to honour Klaus Vogel.
Transfer Pricing and Value Creation
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
Residence of Individuals Under Tax Treaties and EC Law
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.
