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Author: Isabel Verlinden
Publisher:
ISBN: 9789087224868
Category :
Languages : en
Pages :
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Book Description
Author: Isabel Verlinden
Publisher:
ISBN: 9789087224868
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: Isabel Verlinden
Publisher:
ISBN: 9789087224882
Category :
Languages : en
Pages :
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Book Description
Author: Isabel Verlinden
Publisher:
ISBN: 9789080693173
Category :
Languages : en
Pages : 583
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Book Description
Author: Isabel Verlinden
Publisher:
ISBN: 9789081207300
Category : Intellectual property
Languages : en
Pages : 839
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Book Description
Author: Karol Dziwinski
Publisher: Kluwer Law International B.V.
ISBN: 9403540508
Category : Law
Languages : en
Pages : 243
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Book Description
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
Author: Shu-Chien Chen
Publisher: Kluwer Law International B.V.
ISBN: 9403532963
Category : Law
Languages : en
Pages : 471
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Book Description
International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Author: Annika Streicher
Publisher: Linde Verlag GmbH
ISBN: 3709413001
Category : Law
Languages : en
Pages : 533
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Book Description
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.
Author: Felix Frank
Publisher: Packt Publishing Ltd
ISBN: 178839772X
Category : Computers
Languages : en
Pages : 797
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Book Description
Start pulling the strings of your IT infrastructure effectively with Puppet – learn how to configure, customize and manage your systems more intelligently in an enterprise deployment. About This Book Step-by-step instructions to jump start your Puppet deployment and automate your IT configurations Design, implement, and deploy Puppet in your infrastructure and tackle everyday IT infrastructure challenges Gain expert understanding of Puppet's latest and most advanced features Who This Book Is For If you're an experienced IT professional and a new Puppet user, this course will provide you with all you need to know to go from installation to advanced automation. What You Will Learn Write and employ individual Puppet manifests Understand how Puppet implements system abstraction Use Puppet to manage network, cloud, and virtualization devices Manage and test the Puppet code workflow Tweak, hack, and adapt the Puppet extension points Use exported resources to orchestrate change between machines Debug a puppetserver using Java techniques In Detail Puppet is a configuration management tool that allows you to automate all your IT configurations, giving you control. It was written for and by system administrators to manage large numbers of systems efficiently and prevent configuration drifts. Puppet gives you control of what you do to each node, when you do it, and how you do it.This Learning Path will take you from the basics of Puppet to extending it and then mastering it. We will start off with a primer on Puppet, its installation and get a sneak peek under its hood. We will then move on to designing and deploying your Puppet architecture, learning best practices for writing reusable and maintainable code, and executing, testing, and deploying Puppet across your systems. Finally, we will deal with problems of scale and exceptions in your code, automate workflows, and support multiple developers working simultaneously.This course is based on the following books: Puppet 4 Essentials - Second Edition Extending Puppet - Second Edition Mastering Puppet - Second Edition Style and approach This learning path follows a practical approach, starting from the basic commands to advanced aspects. Through a series of examples you will learn the most important skills essential to manage your IT infrastructure effectively.
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 370941010X
Category : Law
Languages : en
Pages : 176
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Book Description
Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
Author: Danette McGilvray
Publisher: Academic Press
ISBN: 0128180161
Category : Computers
Languages : en
Pages : 376
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Book Description
Executing Data Quality Projects, Second Edition presents a structured yet flexible approach for creating, improving, sustaining and managing the quality of data and information within any organization. Studies show that data quality problems are costing businesses billions of dollars each year, with poor data linked to waste and inefficiency, damaged credibility among customers and suppliers, and an organizational inability to make sound decisions. Help is here! This book describes a proven Ten Step approach that combines a conceptual framework for understanding information quality with techniques, tools, and instructions for practically putting the approach to work – with the end result of high-quality trusted data and information, so critical to today’s data-dependent organizations. The Ten Steps approach applies to all types of data and all types of organizations – for-profit in any industry, non-profit, government, education, healthcare, science, research, and medicine. This book includes numerous templates, detailed examples, and practical advice for executing every step. At the same time, readers are advised on how to select relevant steps and apply them in different ways to best address the many situations they will face. The layout allows for quick reference with an easy-to-use format highlighting key concepts and definitions, important checkpoints, communication activities, best practices, and warnings. The experience of actual clients and users of the Ten Steps provide real examples of outputs for the steps plus highlighted, sidebar case studies called Ten Steps in Action. This book uses projects as the vehicle for data quality work and the word broadly to include: 1) focused data quality improvement projects, such as improving data used in supply chain management, 2) data quality activities in other projects such as building new applications and migrating data from legacy systems, integrating data because of mergers and acquisitions, or untangling data due to organizational breakups, and 3) ad hoc use of data quality steps, techniques, or activities in the course of daily work. The Ten Steps approach can also be used to enrich an organization’s standard SDLC (whether sequential or Agile) and it complements general improvement methodologies such as six sigma or lean. No two data quality projects are the same but the flexible nature of the Ten Steps means the methodology can be applied to all. The new Second Edition highlights topics such as artificial intelligence and machine learning, Internet of Things, security and privacy, analytics, legal and regulatory requirements, data science, big data, data lakes, and cloud computing, among others, to show their dependence on data and information and why data quality is more relevant and critical now than ever before. Includes concrete instructions, numerous templates, and practical advice for executing every step of The Ten Steps approach Contains real examples from around the world, gleaned from the author’s consulting practice and from those who implemented based on her training courses and the earlier edition of the book Allows for quick reference with an easy-to-use format highlighting key concepts and definitions, important checkpoints, communication activities, and best practices A companion Web site includes links to numerous data quality resources, including many of the templates featured in the text, quick summaries of key ideas from the Ten Steps methodology, and other tools and information that are available online
