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Author: Darren Henley
Publisher:
ISBN: 9781783968831
Category :
Languages : en
Pages : 0
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Book Description
Author: Darren Henley
Publisher:
ISBN: 9781783968831
Category :
Languages : en
Pages : 0
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Book Description
Author: Marjaana Helminen
Publisher: Kluwer Law International B.V.
ISBN: 9041183957
Category : Law
Languages : en
Pages : 379
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Book Description
The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Author:
Publisher:
ISBN:
Category : Civil procedure
Languages : en
Pages : 728
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Book Description
Author:
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages : 988
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Book Description
Author: Judith Rodin
Publisher: PublicAffairs
ISBN: 1610394712
Category : Social Science
Languages : en
Pages : 382
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Book Description
Building resilience -- the ability to bounce back more quickly and effectively -- is an urgent social and economic issue. Our interconnected world is susceptible to sudden and dramatic shocks and stresses: a cyber-attack, a new strain of virus, a structural failure, a violent storm, a civil disturbance, an economic blow. Through an astonishing range of stories, Judith Rodin shows how people, organizations, businesses, communities, and cities have developed resilience in the face of otherwise catastrophic challenges: Medellin, Colombia, was once the drug and murder capital of South America. Now it's host to international conferences and an emerging vacation destination. Tulsa, Oklahoma, cracked the code of rapid urban development in a floodplain. Airbnb, Toyota, Ikea, Coca-Cola, and other companies have realized the value of reducing vulnerabilities and potential threats to customers, employees, and their bottom line. In the Mau Forest of Kenya, bottom-up solutions are critical for dealing with climate change, environmental degradation, and displacement of locals. Following Superstorm Sandy, the Rockaway Surf Club in New York played a vital role in distributing emergency supplies. As we grow more adept at managing disruption and more skilled at resilience-building, Rodin reveals how we are able to create and take advantage of new economic and social opportunities that offer us the capacity to recover after catastrophes and grow strong in times of relative calm.
Author: Guglielmo Maisto
Publisher: IBFD
ISBN: 9087221398
Category : Corporations
Languages : en
Pages : 1093
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Book Description
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Author: Carola Boehm
Publisher: Emerald Group Publishing
ISBN: 1838677275
Category : Education
Languages : en
Pages : 241
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Book Description
A timely exploration of where creative practices and arts live in our higher education communities. How do creatives shape this creative education ecosystem? How does art provide an interface between what is within and outside of our knowledge institutions? And why should all of this matter for our communities?
Author: David Amigoni
Publisher: Routledge
ISBN: 1351866362
Category : Language Arts & Disciplines
Languages : en
Pages : 303
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Book Description
This collection begins with two premises: that our understanding of the nature and forms of creativity in later life remains limited and that dialogue between specialists in gerontology, the arts and humanities can produce the crucial new insights that are so obviously needed. Representing the outcome of ongoing dialogue across the disciplinary divide, the contributions of this volume reflect anew on what we share and how we differ; creating new narratives so as to build an understanding of late-life creativity that goes far beyond the narrow confines of the pervasively received idea of ‘late style’. Creativity in Later Life encompasses a range of personal reflections and discussions of the boundaries of creativity, including: Canonical artistic achievements to community art projects Narratives of carers for those living with dementia Analyses of creative theory Through these insightful chapters, the authors consequently offer an understanding of creativity in later life as varied, socialised and - above all - located in the cultural and economic circumstances of the here and now. This title will appeal to academics, practitioners and students in the various gerontological, arts and humanities fields; and to anyone with an interest in the nature of creativity in later life and the forms it takes.
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Author:
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages : 972
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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.
