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The Taxation of Permanent Establishments
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
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...
Money
"Judged by the standard of popularity, "Money" may be said to rank among M. Zolas notable achievements . . . This is not surprising, as the book deals with a subject of great interest to every civilized community."--Ernest Alfred Vizetelly.
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 ...
Dean's Domain
Up-close, behind-the-scenes biography of the winningest coach in college basketball history.
Money
After a disastrous speculation, Aristide Saccard was forced to sell his mansion and to cast about for means of creating a fresh fortune. Chance made him acquainted with Hamelin, an engineer whose residence in the East had suggested to him financial schemes which at once attracted the attention of Saccard. With a view to financing these schemes the Universal Bank was formed, and by force of advertising became immediately successful. Emboldened by success, Saccard launched into wild speculation.
The Complete Works of Emile Zola. Illustrated
"The Complete Works of Emile Zola" is an extensive collection that brings together the masterful literary contributions of the renowned French author Emile Zola. This anthology encompasses Zola's notable novels, including "Therese Raquin," "Germinal," "Nana," and the monumental "Rougon-Macquart" cycle. Zola's works are characterized by their meticulous realism, unflinching social commentary, and vivid portrayal of human struggles. In "Therese Raquin," he delves into the dark realms of passion, guilt, and remorse. "Germinal" offers a powerful exploration of the harsh realities faced by miners and the social injustices of the 19th-century industrial world. "Nana" presents a mesmerizing charact...
Delphi Complete Works of Emile Zola (Illustrated)
Émile Zola was the most prominent French novelist of the late nineteenth century. He was noted for his theories of naturalism, which permeate his monumental 20-novel series ‘Les Rougon-Macquart’. Recognised in his lifetime as one of the greatest novelists of his era, Zola was also as a man of action, a defender of truth and justice, and a champion of the poor and persecuted. For the first time in publishing history, this eBook presents Zola’s complete works, with numerous illustrations, rare texts, informative introductions and the usual Delphi bonus material. (Version 3) * Beautifully illustrated with images relating to Zola’s life and works * Concise introductions to the novels an...
