A Guide to the Anti-Tax Avoidance Directive

A Guide to the Anti-Tax Avoidance Directive PDF Author: Werner Haslehner
Publisher: Edward Elgar Publishing
ISBN: 178990577X
Category : Law
Languages : en
Pages : 364

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Book Description
This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.

A Guide to the Anti-Tax Avoidance Directive

A Guide to the Anti-Tax Avoidance Directive PDF Author: Werner Haslehner
Publisher: Edward Elgar Publishing
ISBN: 178990577X
Category : Law
Languages : en
Pages : 364

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Book Description
This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264241132
Category :
Languages : en
Pages : 458

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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

Hybrid Financial Instruments, Double Non-Taxation and Linking Rules

Hybrid Financial Instruments, Double Non-Taxation and Linking Rules PDF Author: Félix Daniel Martínez Laguna
Publisher:
ISBN: 9789403510743
Category :
Languages : en
Pages : 384

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Book Description
Double non-taxation stemming from hybrid financial instruments and the solutions provided by the OECD and the European Union for tackling such an outcome are the target of this publication. It focuses on the economic and legal features of debt and equity instruments as well as hybrid financial instruments from an interdisciplinary perspective where economics, corporate law, financial accounting law, regulatory law and tax law are present. The different qualification of hybrid financial instruments within and without jurisdictions may lead to double non-taxation across borders, which is one of the main issues of concern to the international tax community.

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots PDF Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 148436399X
Category : Business & Economics
Languages : en
Pages : 45

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Book Description
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

A Guide to the European VAT Directives

A Guide to the European VAT Directives PDF Author: Julie Kajus
Publisher:
ISBN: 9789087225186
Category :
Languages : en
Pages : 1668

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Book Description
Resumen del editor. "Published annually, this two-volume set provides a comprehensive overview of the most essential parts of VAT Directives in Europe. Volume 1 offers a systematic survey of the implications of the legal principles on indirect tax matters and of the VAT rules of the European Union in force, and a discussion of the case law of the Court of Justice of the European Union in indirect tax matters, particularly in VAT. Volume 2 provides an (unofficial) integrated text of Directive 77/388/EEC of 17 May 1977 (the Sixth Directive as amended by subsequent directives, treaties of accession and regulations), as applicable until 1 January 2007. The articles of Council Regulation (EC) No. 1777/2005 of 17 October 2005, laying down implementing measures, are indicated under the articles of the Sixth Directive to which they relate. The latest directive integrated into the text is Directive 2006/98/EC of 20 December 2006. This integrated text is unofficial in nature, since headings and footnotes have been added and, where relevant, the text of other directives inserted. On 28 November 2006, Directive 2006/112/EC on the common system of value added tax (the Recast of the First and Sixth VAT Directives) was adopted, entering into force on 1 January 2007. In order to improve the drafting quality, the text of the Sixth Directive has undergone numerous changes. Although the changes do not affect its substantive content, they do alter the format with the 53 articles of the Sixth Directive divided into 414 new articles, of which article 411 repeals the Sixth Directive as set out in this integrated text "

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264267999
Category :
Languages : en
Pages : 326

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Book Description
This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

The Routledge Companion to Tax Avoidance Research

The Routledge Companion to Tax Avoidance Research PDF Author: Nigar Hashimzade
Publisher: Routledge
ISBN: 1317377079
Category : Business & Economics
Languages : en
Pages : 676

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Book Description
An inherently interdisciplinary subject, tax avoidance has attracted growing interest of scholars in many fields. No longer limited to law and accounting, research increasingly has been conducted from other perspectives, such as anthropology, business ethics, corporate social responsibility, and economic psychology. This was –recently stimulated by politicians, mass media, and the public focussing on tax avoidance after the global financial and economic crisis put a squeeze on private and public finances. New challenges were posed by changing definitions and controversies in the interpretation of tax avoidance concept, as well as a host of new rules and policies that need to be fully understood. This collection provides a comprehensive guide to students and academics on the subjects of tax avoidance from an interdisciplinary perspective, exploring the areas of accounting, law, economics, psychology, and sociology. It covers global as well as regional issues, presents a discussion of the definition, legality, morality, and psychology of tax avoidance, and provides guidance on measurement of economic effect of tax avoidance activities. With a truly international selection of authors from the UK, North America, Africa, Asia, Australasia, Middle East, and continental Europe, with well-known experts and rising stars of the field, the contributors cover the entire terrain of this important topic. The Routledge Companion to Tax Avoidance Research is a ground-breaking attempt to bring together scholarly research in tax avoidance, offering rigorous academic analysis of an important and hotly debated issue in a structured and balanced way.

The Effect of Directives Within the Area of Direct Taxation on the Interpretation and Application of Tax Treaties

The Effect of Directives Within the Area of Direct Taxation on the Interpretation and Application of Tax Treaties PDF Author: Mees Vergouwen
Publisher: Kluwer Law International B.V.
ISBN: 9403509171
Category : Law
Languages : en
Pages : 351

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Book Description
In recognition of the considerable attention in recent years given to the effect of EU directives on tax treaties, this important book for the first time brings a combined public international law and European Union law perspective to bear on certain directives – primarily the Parent-Subsidiary Directive, the Merger Directive, the Interest and Royalty Directive, and the Anti-Tax Avoidance Directives – and their interaction with tax treaties concluded by EU Member States. In this area of direct international taxation, the author examines the effect of tax treaties on both the interpretation and application of directives in depth. In clarifying how directives can affect or are allowed to affect, tax treaties, the book provides detailed analyses of such aspects as the following: status of directives under public international law, including relevant provisions of the Vienna Convention on the Law of Treaties and the OECD Model Tax Treaty; whether national law aimed at implementing a directive may be able to override a tax treaty or may be overridden by such a tax treaty; whether the lex posterior and lex specialis conflict rules under public international law are applicable to conflicts between directives and tax treaties; the role of directives under the interpretative provision of the Vienna Convention on the Law of Treaties, the OECD Model Tax Treaty and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting; legal basis and application of the duty of consistent interpretation to tax treaties; and scope of the primacy of directives with respect to tax treaties. The book offers insightful and well-informed recommendations aimed at aligning the ‘allowed’ effect under public international law and the ‘required’ effect under the laws of the European Union of the directives on tax treaties, with a view to ensuring that directives affect tax treaties in such a way that tax treaties cannot prevent achievement of the result of a directive. The analysis is based primarily on legal doctrines, literature, and case law of the CJEU, ICJ, and arbitral tribunals. As a highly informative and closely reasoned guide that offers clear perspectives on resolving any conflict that may arise between a directive and a tax treaty, this book will be of inestimable value for tax practitioners and advisers, judges, policymakers, tax authorities, and academics whose work involves tax treaties concluded by EU Member States.

Introduction to European Tax Law on Direct Taxation

Introduction to European Tax Law on Direct Taxation PDF Author: Lukasz Adamczyk
Publisher: Linde Verlag GmbH
ISBN: 3709413508
Category : Law
Languages : en
Pages : 315

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Book Description
Basic knowledge of European Tax Law This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. The eighth edition adds new updates on the most essential changes and new case law of the CJEU in the field of European direct taxation. Furthermore, due to its particular importance, the EU Global Minimum Tax Directive is now covered in a separate chapter.

European Union Corporate Tax Law

European Union Corporate Tax Law PDF Author: Christiana HJI Panayi
Publisher: Cambridge University Press
ISBN: 1108839029
Category : Business & Economics
Languages : en
Pages : 397

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Book Description
What is the impact of European Union law on Member State corporate tax systems and the cross-border activities of companies?