Switzerland in International Tax Law PDF Download
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Author: Xavier Oberson
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 280
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Book Description
An introduction to Swiss international tax law, its characteristics and guiding principles. Particular attention is paid to the special tax relief granted to Swiss resident individuals and corporations, as well as to the complex rules for the avoidance of treaty abuse. The authors also discuss the Swiss case law developed for the avoidance of intercantonal double taxation, the tax credit and the Swiss approaches both to transfer pricing and the implementation of mutual agreement procedures.
Author: Xavier Oberson
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 280
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Book Description
An introduction to Swiss international tax law, its characteristics and guiding principles. Particular attention is paid to the special tax relief granted to Swiss resident individuals and corporations, as well as to the complex rules for the avoidance of treaty abuse. The authors also discuss the Swiss case law developed for the avoidance of intercantonal double taxation, the tax credit and the Swiss approaches both to transfer pricing and the implementation of mutual agreement procedures.
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
Author: Harvard Law School. International Tax Program
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1456
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Book Description
Author: Luc De Broe
Publisher: IBFD
ISBN: 9087220359
Category : Corporations
Languages : en
Pages : 1146
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Book Description
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Author: Robert J. Danon
Publisher:
ISBN: 9782802717126
Category : Express trusts
Languages : en
Pages : 411
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Book Description
Author: Carol Gregor Luethi
Publisher:
ISBN: 9783744830096
Category :
Languages : en
Pages : 288
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Book Description
International Edition (Distribution in USA, Canada, Great Britain, Australia) Both the Federal Act on Direct Federal Taxation (DBG) as well as the Federal Act on the Harmonisation of Income Taxes of the Cantons and Communities (StHG) allow non-working foreign citizens with Swiss residency to benefit from a special kind of income and wealth taxation. This historically anchored regulation has attracted wealthy foreign citizens to take up residency in Switzerland and will likely continue to do so. For the first time in over 150 years of lump-sum taxation history this book gives a systematical and comprehensive overview on the revised regulations and includes several side effects of taxation. *** As lector, the manner of concentration to the topic, the comprehensive processing of the literature, as well as with the changing legal bases in the federal state, and in the cantons, appears to me as impressive. Indeed, this extremely successful master thesis is qualified for an award ceremony. It is because of this that Mr. Luethi received, from my side, the predicate summa cum laude. (Prof. Dr. Bernhard Zwahlen, President of the advisory board of the Swiss Institute of Taxation, Zurich) *** Carol Gregor Luethi has very extensively investigated lump-sum taxation. Beneath the historical and current developments he was not afraid to investigate the practice in the cantons, what is very meritorious as there partly exist large differencies. Also, for this topic, existing literature and judicature is seamlessly integrated into his analysis. So far, only one scientifical work that dealed in a related depth with lump-sum taxation in Switzerland, existed, which is namely the one of Prof. Marco Bernasconi from 1983. Already with the introduction of the StHG but with the thigthening of lump-sum taxation more than ever this existing work is outdated. Carol Gregor Luethis scientific work is closing this gap. His substantiated investigation even goes beyond existing work, with side glance
Author: Reuven S. Avi-Yonah
Publisher: Edward Elgar Publishing
ISBN: 1788978498
Category : Double taxation
Languages : en
Pages : 231
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Book Description
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
Author: Guglielmo Maisto (jurist.)
Publisher: IBFD
ISBN: 9076078823
Category : Law
Languages : en
Pages : 375
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Book Description
The book identifies linguistic issues arising in bilateral income tax conventions and presents an in-dept analysis of tax treaty policies on multilingualism and the administrative practice and case law on the issues raised by the translation of treaties. Individual country surveys discuss the use of legal concepts, including those that do not exist in the legal system of one of the two contracting states and the way such concepts should be interpreted in such state (e.g. trust). Further, the use of concepts in one state that are similar but not identical to a treaty concept that is well known only in the other state (e.g. droit d'auteur vs copyright) are presented. The book also includes special reports on multilingual issues under both art. 33 of the Vienna Convention and art. 3(2) of the OECD Model Convention and Commentaries. Finally, a specific chapter is devoted to the EU law aspects and a review of the jurisprudence of the European Court of Justice (ECJ).
Author: Switzerland
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages :
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Book Description
Author: Lorenzo Riccardi
Publisher: Springer Science & Business Media
ISBN: 3319002759
Category : Law
Languages : en
Pages : 278
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Book Description
The People’s Republic of China’s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation’s rise to the world’s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China’s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China’s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China’s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis. Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.
