Limitation on Benefits Clauses in Double Taxation Conventions PDF Download
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Author: Félix Alberto Vega Borrego
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 438
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Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Author: Félix Alberto Vega Borrego
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 438
Get Book Here
Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Author: Douglas R. Andrew
Publisher: Business Plus
ISBN: 0446511218
Category : Business & Economics
Languages : en
Pages : 258
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Book Description
Expert financial planner Douglas R. Andrew's bestselling definitive guide on managing your money, now available in Spanish. We've been hearing the same advice on managing your money for years - always prepay your mortgage. Always invest in a 401(k). Defer your taxes for as long as possible. What if someone told you that following that advice would be a waste of your money? In his groundbreaking book on personal finance, Douglas R. Andrew debunks these myths, along with several others, and gives essential knowledge on how to wisely manage your money and win back your "missed fortune." By following tips such as investing your home equity, discovering hidden tax breaks, and turning your life insurance policy into an investment, you can discover millions of dollars worth of hidden assets. Now, this best-selling book is being brought to the Spanish language audience. Translated by Mario Cisneros, a personal finance expert, the translated book will serve the large audience who have been clamoring for it since Missed Fortune 101's intial English language publication.
Author: Nicolás Malumián
Publisher: Oxford University Press
ISBN: 0195388216
Category : Law
Languages : en
Pages : 426
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Book Description
The growing interest in investment in Latin America - particularly in commodities production and real estate development - has increased the use of trusts as investment vehicles throughout Latin America. Written for the English-speaking practitioner, the book covers Argentina, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Honduras, México, Panamá, Paraguay, Perú, Uruguay and Venezuela and provides a practical, clear, and thorough explanation of trusts as legal vehicles for investment in Latin American countries. Trusts in Latin America provides a comprehensive, comparative review of statutes, case law, and examples of trusts in Latin America, and also highlights differences between these countries and common-law systems.
Author: International Institute for Democracy and Electoral Assistance
Publisher:
ISBN:
Category : Civil rights
Languages : en
Pages : 332
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Book Description
Author: Mónica M. Salas Landa
Publisher: University of Texas Press
ISBN: 1477328718
Category : Art
Languages : en
Pages : 309
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Book Description
An examination of the failures of the Mexican Revolution through the visual and material records.
Author: Alfonso W. Quiroz
Publisher: Woodrow Wilson Center Press
ISBN: 9780801891281
Category : History
Languages : en
Pages : 556
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Book Description
The pervasiveness of corruption has been aided by the readiness of both Peruvians and the international community to turn a blind eye.
Author: Tasha Fairfield
Publisher: Cambridge University Press
ISBN: 1107088372
Category : Business & Economics
Languages : en
Pages : 365
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Book Description
This book identifies sources of power that help business and economic elites influence policy decisions.
Author: University of Texas at Austin. Library. Latin American Collection
Publisher:
ISBN:
Category : Latin America
Languages : en
Pages : 756
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Book Description
Author: Pedro-Pablo Kuczynski
Publisher: Columbia University Press
ISBN: 0881324515
Category : Business & Economics
Languages : en
Pages : 386
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Book Description
This volume is a successor of sorts to the Institute's 1986 volume Toward Renewed Economic Growth in Latin America, which blazed the trail for the market-oriented economic reforms that were adopted in Latin America in the subsequent years. It again presents the work of a group of leading Latin American economists who were asked to think about the nature of the economic policy agenda that the region should be pursuing after a decade that was punctuated by crises, achieved disappointingly slow growth, and saw no improvement in the region's highly skewed income distribution. The study diagnoses the first-generation (liberalizing and stabilizing) reforms that are still lacking, the complementary second-generation (institutional) reforms that are necessary to provide the institutional infrastructure of a market economy with an egalitarian bias, and the new initiatives that are needed to crisis-proof the economies of the region to end its perpetual series of crises. Contributors: Daniel Artana, Nancy Birdsall, Roberto Bouzas, Saúl Keifman, Pedro-Pablo Kuczynski, Ricardo López Murphy, Claudio de Moura Castro, Fernando Navajas, Patricio Navia, Liliana Rojas-Suarez, Jaime Saavedra, Miguel Székely, Andrés Velasco, John Williamson, and Laurence Wolff.
Author: Nora Lustig
Publisher: Brookings Institution Press
ISBN: 0815740476
Category : Political Science
Languages : en
Pages : 1437
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Book Description
Edited by Nora Lustig, the Commitment to Equity Handbook: Estimating the Impact of Fiscal Policy on Inequality and Poverty (Brookings Institution Press and CEQ Institute-Tulane University, 2nd edition, 2022) is a unique manual on the theory and practical methods to estimate the impact of taxation and public spending on inequality and poverty. In addition, the second edition covers frontier topics such as alternative approaches to measure the redistributive effect of education, health, and infrastructure spending. Policymakers, social planners, and economists are provided with a step-by-step guide to applying fiscal incidence analysis, illustrated by country studies. The 2nd edition of the Handbook has two volumes. Volume 1 is comprised of Part I, Methodology, describes what a CEQ Assessment© is and presents the theoretical underpinnings of fiscal incidence analysis and the indicators used to assess the distributive impact and effectiveness of fiscal policy. Part II, Implementation, presents the methodology on how taxes, subsidies, and social spending should be allocated. It includes a step-by step guide to completing the CEQ Master Workbook©, a multi-sheet Excel file that houses detailed information on the country’s fiscal system and the results used as inputs for policy discussions, academic papers, and policy reports. Part III, “Applications,” presents applications of the CEQ framework to low- and middle-income countries and includes simulations of policy reforms. In this 2nd edition, chapters 1, 6, and 8 have been significantly updated and two new country studies have been added to Part III. Parts IV (updated), V (new), and VI (new) are available online only. Part IV contains the CEQ Assessment’s main tools. Part V includes the databases housed in the CEQ Data Center on Fiscal Redistribution. Part VI contains the CEQ Institute’s microsimulation tools. Volume 2 (new) includes a collection of chapters whose purpose is to expand the knowledge and methodological frontiers to sharpen even further the analysis of fiscal policy’s redistributive impact. Topics include: alternative approaches to value in-kind education and health services; alternative methods to evaluate spending on infrastructure; corporate taxes and taxation on capital incomes; inter-temporal fiscal incidence and the redistributive consequences of social insurance pensions; fiscal redistribution, macroeconomic stability and growth; and, the political economy of fiscal redistribution.
