Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
ISBN: 9403535520
Category : Law
Languages : en
Pages : 252
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Book Description
Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
ISBN: 9403511664
Category : Law
Languages : en
Pages : 340
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Book Description
Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.
Author: Simon Young
Publisher: Federation Press
ISBN: 9781862876477
Category : History
Languages : en
Pages : 534
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Book Description
This book is a broad and detailed examination of the native title jurisprudence in the US, Canada, New Zealand and Australia, with a specific focus on the handling of Indigenous community changes in each country's case law.
Author: Jelena Madir
Publisher: BRILL
ISBN: 9004414126
Category : Law
Languages : en
Pages : 280
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Book Description
In Sanctions Regimes of Multilateral Development Banks: What Process is Due, Jelena Madir examines the type of due process rights and the level of transparency that should characterise sanctions regimes of multilateral development banks.
Author: Bradley C. S. Watson
Publisher: University of Notre Dame Pess
ISBN: 0268106991
Category : Political Science
Languages : en
Pages : 325
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Book Description
At its core this book is intellectual history, tracing the work of progressive historians as they in turn wrote the history of progressivism. In Progressivism: The Strange History of a Radical Idea, Bradley C. S. Watson presents an intellectual history of American progressivism as a philosophical-political phenomenon, focusing on how and with what consequences the academic discipline of history came to accept and propagate it. This book offers a meticulously detailed historiography and critique of the insularity and biases of academic culture. It shows how the first scholarly interpreters of progressivism were, in large measure, also its intellectual architects, and later interpreters were in deep sympathy with their premises and conclusions. Too many scholarly treatments of the progressive synthesis were products of it, or at least were insufficiently mindful of two central facts: the hostility of progressive theory to the Founders’ Constitution and the tension between progressive theory and the realm of the private, including even conscience itself. The constitutional and religious dimensions of progressive thought—and, in particular, the relationship between the two—remained hidden for much of the twentieth century. This pathbreaking volume reveals how and why this scholarly obfuscation occurred. The book will interest students and scholars of American political thought, the Progressive Era, and historiography, and it will be a useful reference work for anyone in history, law, and political science.
Author: Götz Ferdinand Kaufmann
Publisher: Götz Kaufmann
ISBN:
Category :
Languages : en
Pages : 424
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Book Description
Author: Allen M. Howard
Publisher: BRILL
ISBN: 9004139133
Category : Social Science
Languages : en
Pages : 385
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Book Description
In this collection authors apply spatial analysis to case studies of social, economic, and political dynamics in West, Central, and East Africa during the nineteenth and twentieth century. Also included is a lengthy essay re-interpreting tropical Africa, 1800-1930, using spatial theory.
Author: Jose Dalisay Jr.
Publisher: Anvil Publishing, Inc.
ISBN: 9712733157
Category : Biography & Autobiography
Languages : en
Pages : 101
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Book Description
An Unknown Chapter in Philippine History Emmanuel Quiason Yap possessed a unique perspective on world affairs. This was largely a product of his upbringing and life experience, which underpinned his great love of country. Through his life, we see a clear view of the road not taken. This book portrays one of the most significant and turbulent chapters in Philippine history in this context. The period from the late 1950s to the early 1970s witnessed a resurgence of the nationalist movement, the election of Ferdinand Marcos as president, the establishment of the Communist Party of the Philippines, the First Quarter Storm, the bombing of Plaza Miranda, and the declaration of martial law. Manoling Yap cast a different light on these events, including the roles of Marcos, and Ninoy and Cory Aquino. Inevitably, many disagreed with his analysis and some dismissed him as a Communist. Ironically, it was during this period that his career reached both its zenith and nadir. Because of illness, he was unable to write his autobiography as he had always intended. But his analysis and interpretation of important events present an alternative viewpoint that must be known. This is Manoling Yap’s story
Author: Frances Westley
Publisher: Edward Elgar Publishing
ISBN: 1786431157
Category :
Languages : en
Pages : 288
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Book Description
In a time where governments and civil society organizations are putting ever-greater stock in social innovation as a route to transformation, understanding what characterizes social innovation with transformative potential is important. Exciting and promising ideas seem to die out as often as they take flight, and market mechanisms, which go a long way towards contributing to successful technical innovations, play an insignificant role in social innovations. The cases in this book explore the evolution of successful social innovation through time, from the ideas which catalysed social and system entrepreneurs to create new processes, platforms, projects and programs to fundamental social shifts in culture, economics, laws and policies which occurred as a result. In doing so, the authors shed light on how to recognize transformative potential in the early stage innovations we see today.
Author: Michelle Markham
Publisher: Kluwer Law International B.V.
ISBN: 9041140727
Category : Law
Languages : en
Pages : 408
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Book Description
Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ‘tax risk appetite’ on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) – arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.
