Introducing a Global Minimum Tax (Pillar Two) in Canada PDF Download
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Author: Jinyan Li
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
This paper provides a high-level overview of the pillar two global minimum tax in terms of its policy objectives, technical design, and implications for Canada. After teasing out some significant known and unknown challenges, the paper offers some thoughts on whether and, if so, how and when Canada should proceed with implementation.
Author: Jinyan Li
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
This paper provides a high-level overview of the pillar two global minimum tax in terms of its policy objectives, technical design, and implications for Canada. After teasing out some significant known and unknown challenges, the paper offers some thoughts on whether and, if so, how and when Canada should proceed with implementation.
Author: Ana Cebreiro Gómez
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
In October 2021, a historic two-pillar international agreement was reached among 137 countries of the OECD/G20 Inclusive Framework on BEPS to address the twin challenges of globalization and digitalization. Pillar One will reallocate tax revenues to the country of the consumer. Pillar Two introduces a global minimum effective tax for MNEs (GMT). This paper focuses on implementation of the GMT. It provides an overview of the core GMT rules, examines implementation by countries thus far, evaluates the key policy considerations (including the impact on tax incentives), and provides a framework for evaluation of the implementation options. The paper also makes recommendations on practical steps in the implementation process, including administrative issues and consultation with key stakeholders. These discussions are expected to be particularly relevant for developing countries.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
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Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264202714
Category :
Languages : en
Pages : 44
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Book Description
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
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: OECD
Publisher: OECD Publishing
ISBN: 9264438181
Category :
Languages : en
Pages : 651
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Book Description
This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by workers. Taxing Wages 2021 includes a special feature entitled: “Impact of COVID-19 on the Tax Wedge in OECD Countries”.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264162941
Category :
Languages : en
Pages : 82
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Book Description
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author: Oecd
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264241374
Category :
Languages : en
Pages : 100
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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 12.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264007229
Category :
Languages : en
Pages : 158
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Book Description
The increased speed and mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. This book presents a two-part look at existing OECD positions on these issues.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264424083
Category :
Languages : en
Pages : 355
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Book Description
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
