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Author: Ruediger Urbahns
Publisher: GRIN Verlag
ISBN: 3638026191
Category : Business & Economics
Languages : en
Pages : 48
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Book Description
Document from the year 2008 in the subject Business economics - Accounting and Taxes, grade: keine, , language: English, abstract: This booklet is specifically addressed to foreign licensors and its tax advisors receiving licence income from German sources and which are faced or threatened with tax deduction in Germany. The intention of this book is to provide you with an adequate but hardly exhaustive understanding of the German tax consequences and also opportunities as a foreign licensor. After reading this book you should have a good understanding of you rights as taxpayer and should be able deal with the main tax issues as foreign licensor in Germany. Important Notice: The Tax Act of 2009 has changed large parts of the section 50a German Income Tax Act and thus the tax withholding procedure. In many cases a deduction of related expenses is now possible at least to a certain extent. Still not so, however, for royalty payments for which reason the domestic withholding tax rate has been reduced to 15% (plus solidarity surcharge), regardless if the foreign licensor is a corporation or other person.
Author: Ruediger Urbahns
Publisher: GRIN Verlag
ISBN: 3638026191
Category : Business & Economics
Languages : en
Pages : 48
Get Book Here
Book Description
Document from the year 2008 in the subject Business economics - Accounting and Taxes, grade: keine, , language: English, abstract: This booklet is specifically addressed to foreign licensors and its tax advisors receiving licence income from German sources and which are faced or threatened with tax deduction in Germany. The intention of this book is to provide you with an adequate but hardly exhaustive understanding of the German tax consequences and also opportunities as a foreign licensor. After reading this book you should have a good understanding of you rights as taxpayer and should be able deal with the main tax issues as foreign licensor in Germany. Important Notice: The Tax Act of 2009 has changed large parts of the section 50a German Income Tax Act and thus the tax withholding procedure. In many cases a deduction of related expenses is now possible at least to a certain extent. Still not so, however, for royalty payments for which reason the domestic withholding tax rate has been reduced to 15% (plus solidarity surcharge), regardless if the foreign licensor is a corporation or other person.
Author: OECD
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264241237
Category :
Languages : en
Pages : 186
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Book Description
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Author:
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 52
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Book Description
Author: Jonathan Schwarz
Publisher: Kluwer Law International B.V.
ISBN: 9403526319
Category : Law
Languages : en
Pages : 870
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Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Author: Xavier Oberson
Publisher: IBFD
ISBN: 9087220987
Category : Double taxation
Languages : en
Pages : 457
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Book Description
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author:
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 12
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91
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Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1108150381
Category : Law
Languages : en
Pages : 2216
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Book Description
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Author: Martin Feldstein
Publisher: University of Chicago Press
ISBN: 0226241874
Category : Business & Economics
Languages : en
Pages : 338
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Book Description
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
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.
