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Author: Ruud A. de Mooij
Publisher: INTERNATIONAL MONETARY FUND
ISBN: 9781513560922
Category : Business & Economics
Languages : en
Pages : 36
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Book Description
Luxembourg receives ample investment from multinational corporations, in part due to some attractive features in its international tax rules. Around 95 percent of these foreign investments pass through Luxembourg via companies performing holding and/or intra-group financing activities. While their contribution to Luxembourg’s economy is modest relative to their large overall balance sheets, they still generate around 3 percent of GDP in tax revenue, create almost 4500 direct jobs, and spend almost 3 percent of GDP on salaries and purchases of business services. Ongoing changes in the international corporate tax framework pose risks to these economic contributions, which this paper attempts to quantify. It also discusses options for reforms in Luxembourg’s tax system that could help offset adverse revenue and economic effects.
Author: Ruud A. de Mooij
Publisher: INTERNATIONAL MONETARY FUND
ISBN: 9781513560922
Category : Business & Economics
Languages : en
Pages : 36
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Book Description
Luxembourg receives ample investment from multinational corporations, in part due to some attractive features in its international tax rules. Around 95 percent of these foreign investments pass through Luxembourg via companies performing holding and/or intra-group financing activities. While their contribution to Luxembourg’s economy is modest relative to their large overall balance sheets, they still generate around 3 percent of GDP in tax revenue, create almost 4500 direct jobs, and spend almost 3 percent of GDP on salaries and purchases of business services. Ongoing changes in the international corporate tax framework pose risks to these economic contributions, which this paper attempts to quantify. It also discusses options for reforms in Luxembourg’s tax system that could help offset adverse revenue and economic effects.
Author: Philip J. Warner
Publisher: IBFD
ISBN: 9076078610
Category : Aliens
Languages : en
Pages : 588
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Book Description
Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning
Author: Maude Bologne
Publisher: Éditions Larcier
ISBN: 2879984416
Category : Law
Languages : en
Pages : 399
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Book Description
Over the past several years, there has been a steady increase in the number of resident taxpayers subject to the various taxes on income and net worth in Luxembourg. However, until now, no complete and up-to-date documentation has been available to guide taxpayers in the preparation of their tax returns. This book, which is both detailed and highly readable, is a practical response to that information gap. This first English edition is based on tax legislation which is effective in Luxembourg as at 31 December 2018 and provides guidance on how to complete the online corporate income tax, municipal business tax and net worth tax return for resident corporations and how to submit the mandatory electronic declaration. This book undertakes a page-by-page analysis of the tax return form for commercial companies and the annexes to that form and draws attention to the most important laws, regulations and administrative circulars currently in force. The book also incorporates many practical examples. These features make this book an ideal reference guide for resident corporations in Luxembourg.
Author: Marc Schmitz
Publisher:
ISBN: 9789087223366
Category : Aliens
Languages : en
Pages : 610
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Book Description
Luxembourg in International Tax' takes an in-depth look at corporate taxation in Luxembourg and the tax issues that may be of interest in an international environment. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear explanation of corporate tax in Luxembourg, it is also of interest to locally based practitioners. The first edition rapidly became a standard reference work in Luxembourg tax literature, and its reputation was maintained through the second edition, which continued being referred to and selling long after the date of issue. 0This new edition of the book is updated to incorporate tax developments on the national level up to January 2015, including the latest changes on the exchange of information, advance tax clearances and the codification of the arm’s length standard. It also covers Luxembourg’s intellectual property box regime, private wealth management companies and other investment entities, and the taxation of financing activities in Luxembourg. Furthermore, it contains a new chapter on tax treaties, which provides insight into the particularities of Luxembourg’s treaty network and its interaction with domestic law. 0The book provides a vast amount of up-to-date information combined with an in-depth analysis of business taxation in Luxembourg. It is a valuable guide for international tax experts wishing to gain a better understanding of corporate tax in Luxembourg as well as for locally based practitioners. With numerous examples given in each chapter, it will also be of interest to students.
Author: Marta Castelon
Publisher: Kluwer Law International B.V.
ISBN: 9041195955
Category : Law
Languages : en
Pages : 544
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Book Description
The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.
Author: International Monetary
Publisher: International Monetary Fund
ISBN:
Category : Business & Economics
Languages : en
Pages : 17
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Book Description
Selected Issues
Author: Organisation for Economic Co-operation and Development
Publisher: Organisation for Economic Co-operation and Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 484
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Book Description
Report presenting the main corporate tax provisions in all 24 OECD countries in 1991. Calculates effective corporate tax rates on domestic as well as on international investment for manufacturing industry in these countries and discusses in depth the main relevant tax policy issues with particular emphasis on possible means to reduce tax distortions to international flows of capital.
Author: Roy Rohatgi
Publisher: Springer
ISBN: 9789041198525
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
The taxation of international economic activities presents two essential considerations: revenues must be shared equitably by the nations involved, and those nations must be able to enforce their domestic tax laws. Starting from these requirements of reciprocity and enforcement, the author explains in this book the practical issues affecting international taxation of business income and capital gains. Unlike many books on this complex subject, his approach does not examine the tax perspective of any one country, but proceeds from an identification and analysis of the basic principles of the subject. This entails an understanding of factors, such as: domestic tax laws, rules and practices and how they conflict on cross-border transactions; bilateral tax treaties and their role in resolving international tax conflicts; the use of offshore financial centres in international tax structures and how to choose them; anti-avoidance measures imposed by national taxation authorities; and international tax guidelines and interpretations of bodies such as the Organisation for Economic Cooperation and Development (OECD) and the International Fiscal Association (IFA). Basic International Taxation describes each and all of these elements, weaving them into practical planning guidance providing a fundamental understanding of this subject in a single, easy-to-follow book. It explains those principles of international tax planning that take the costs and risks of international taxation fully into account and thereby optimize the after-tax returns on cross-border transactions. Several important current issues, including the taxation of electronic commerce, are also addressed.
Author: International Monetary Fund. European Dept.
Publisher: International Monetary Fund
ISBN: 1498314546
Category : Business & Economics
Languages : en
Pages : 67
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Book Description
This 2019 Article IV Consultation discusses that Luxembourg’s growth prospects remain favorable, but downside risks arise from a weaker-than-expected global growth, a disorderly Brexit, changes in international tax rules, and a sharp tightening of global financial conditions. Domestically, rising real estate prices could exacerbate already elevated household indebtedness and increase affordability challenges. Fiscal policy should aim to maintain a strong fiscal position and preserve buffers. The government’s plans, while appropriate, will result in a slightly expansionary budget in 2019. The cost and timeline of the planned measures over the medium term remain to be determined. Given risks ahead, including from potential changes in international taxation, Luxembourg should build on its strong fiscal record and preserve sizeable buffers. Structural policies should focus on addressing key gaps in the economy. Further reforms of the pension system are needed to ensure its sustainability, while considering intergenerational equity and trade-offs of various reform options.
Author: International Monetary Fund. European Dept.
Publisher: International Monetary Fund
ISBN: 1475599706
Category : Business & Economics
Languages : en
Pages : 61
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Book Description
Growth has been strong, benefiting from Luxembourg’s major role in intermediating international capital flows, and prospects are good. However, the outlook remains clouded by risks arising from possible global retreat from cross-border integration and policy uncertainty and divergence which could cause financial market volatility; from the international tax transparency and anti-tax avoidance agenda; as well as from new shocks to the euro area economy. Unemployment, moderately high relative to historical standards, mainly reflects skills mismatches, and new jobs have increasingly been taken up by cross-border commuters.
