Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010 PDF Author: Great Britain
Publisher: The Stationery Office
ISBN: 9780105408109
Category : Law
Languages : en
Pages : 436

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Book Description
Royal assent, 18th March 2010. An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite acts. Explanatory notes to assist in the understanding of the Act will be available separately

Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010 PDF Author: Great Britain
Publisher: The Stationery Office
ISBN: 9780105408109
Category : Law
Languages : en
Pages : 436

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Book Description
Royal assent, 18th March 2010. An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite acts. Explanatory notes to assist in the understanding of the Act will be available separately

Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010 PDF Author: Great Britain: H.M. Revenue & Customs
Publisher: The Stationery Office
ISBN: 9780105451488
Category :
Languages : en
Pages : 136

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Book Description
This is an accompanying document to the Taxation (International and Other Provisions) Act 2010, chapter 8 (ISBN 9780105408109) and its explanatory notes (ISBN 9780105608103)

International Taxation of Banking

International Taxation of Banking PDF Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 9403510951
Category : Law
Languages : en
Pages : 468

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Book Description
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Schwarz on Tax Treaties

Schwarz on Tax Treaties PDF 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’.

International Taxation of Manufacturing and Distribution

International Taxation of Manufacturing and Distribution PDF Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 904116667X
Category : Law
Languages : en
Pages : 460

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Book Description
The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.

International Taxation of Energy Production and Distribution

International Taxation of Energy Production and Distribution PDF Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 9041191208
Category : Law
Languages : en
Pages : 407

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Book Description
Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.

Finance Act 2012

Finance Act 2012 PDF Author: Great Britain
Publisher: The Stationery Office
ISBN: 9780105414124
Category : Business & Economics
Languages : en
Pages : 708

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Book Description
The FAO Yearbook of Fishery and Aquaculture Statistics contains all the most updated data on capture production, aquaculture production and commodities. In this new presentation, the complete yearbook package for each of these categories - all the key information and statistical tables - are contained on one CD-ROM, inserted in a booklet that includes general notes, concepts and classifications, and summary tables as well as a pull-out map of FAO major fishing areas. From the CD-ROM, you can download, consult, share and store all the data previously provided in print only. This volume presents world fishery statistics for recent years ending in 2010.

Comparative Income Taxation

Comparative Income Taxation PDF Author: Brian J. Arnold
Publisher: Kluwer Law International B.V.
ISBN: 9403510900
Category : Law
Languages : en
Pages : 667

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Book Description
Comparative Income Taxation A Structural Analysis Fourth Edition Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries’ tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following: classification of business entities; taxation of corporations and their shareholders; corporate organization and restructuring; taxation of partnerships; residence and source taxation; controlled foreign company rules; restrictions on the deduction of interest; courts dealing with tax matters; and effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.

Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th edition

Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th edition PDF Author: David Southern
Publisher: Bloomsbury Publishing
ISBN: 1526507080
Category : Business & Economics
Languages : en
Pages : 269

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Book Description
Brings the reader right up-to-date with the latest tax changes affecting loan relationships and derivative contracts. Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th Edition gives detailed coverage with working examples of the major legislative changes that have been introduced in these areas since the publication of the 10th edition in 2017. It contains chapters dealing with:

A Dictionary of Law

A Dictionary of Law PDF Author: Jonathan Law
Publisher: Oxford University Press
ISBN: 0192523422
Category : Reference
Languages : en
Pages : 1104

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Book Description
This bestselling dictionary is an authoritative and comprehensive source of jargon-free legal information. It contains over 4,800 entries that clearly define the major terms, concepts, processes, and the organization of the English legal system. Now in its ninth edition, it has been fully updated to incorporate recent case law and the latest legislation, such as the Modern Slavery Act 2015, the Brexit legislation, and changes in consumer, tax, and family law. Over 100 new entries have been added, including Article 50, Brexit, the Marriage (Same Sex Couples) Act 2013, and intercountry adoption. In addition, there is a useful Writing and Citation Guide that specifically addresses problems and established conventions for writing legal essays and reports. Now providing more information than ever before, this edition features recommended web links for many entries, which are accessed and kept up to date via the Dictionary of Law companion website. Described by leading university lecturers as 'the best law dictionary' and 'excellent for non-law students as well as law undergraduates', this classic dictionary is an invaluable source of legal reference for professionals, students, and anyone else needing succinct clarification of legal terms. Focusing primarily on English law, it also provides a one-stop source of information for any of the many countries that base their legal system on English law.