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Author: M.H. Martini
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the authors review the progress that the OECD has made in instituting and revising its International Compliance Assurance Programme (ICAP) and suggest ways in which the ICAP could be improved in the future.
Author: M.H. Martini
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the authors review the progress that the OECD has made in instituting and revising its International Compliance Assurance Programme (ICAP) and suggest ways in which the ICAP could be improved in the future.
Author: Ronald Hein
Publisher: Kluwer Law International B.V.
ISBN: 9403519800
Category : Law
Languages : en
Pages : 314
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Book Description
Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the International Compliance Assurance Programme (ICAP), which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing developments in twelve countries (Australia, Austria, Canada, Germany, Italy, Japan, the Netherlands, Norway, Poland, Spain, the United Kingdom, and the United States). Following a general introduction, two opening perspectives on the ICAP are presented, one from the OECD and one from a participating tax administration (the Netherlands), leading to the twelve country reports and a special chapter on transfer pricing, which is the main issue in international tax disputes. Specific elements reviewed include the following: criteria to enter the programme; the range of taxes covered by the programme; real-time consultation procedures; appeal procedures within the programme; the possibility to ‘agree to disagree’ and to continue Co-operative Compliance even in cases of litigation; risk management strategies within tax authorities; corporate administrative compliance burden; and main sources of tax uncertainty. Country reports are contributed by tax professionals and tax academics experienced in dealing with Co-operative Compliance and the ICAP. Each report addresses the same questions, so that all the reports cover the same features of domestic relationship approaches and the ICAP. A final chapter reviews the collected contributions and offers some concluding remarks. Although the ICAP process probably will undergo further adjustments, it is certain that the road to more international cooperation between tax authorities and MNEs is now open. This timely book, as a comparative review of the implementation of the ICAP among leading jurisdictions active in global trade, provides matchless insights into trends, similarities, differences and their implications. It will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.
Author: F. Vincent
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Before hailing the newly minted International Compliance Assurance Programme (ICAP) from the OECD as the panacea to resolve problems of double taxation for multinational enterprises (MNE), the authors thought it would be useful to review and compare the ICAP's salient features with those of other existing programs aimed at resolving double taxation. This paper provides a side-by-side comparison of the various multijurisdictional tools/programs available pursuant to double tax treaties to resolve double taxation in respect of transfer pricing transactions: mutual agreement procedure (MAP); advance pricing arrangements (APAs); simultaneous tax examinations; joint audits; and ICAP. Each of these programs is reviewed as it relates to the following topics: (1) goals; (2) parties; (3) process; (4) documentation required; (5) timing; (6) availability; (7) benefits; and (8) drawbacks.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264424083
Category :
Languages : en
Pages : 355
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Book Description
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Author: United States. Congress. House. Committee on Appropriations. Subcommittee on Energy and Water Development
Publisher:
ISBN:
Category : Energy development
Languages : en
Pages : 2048
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264059598
Category :
Languages : en
Pages : 210
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Book Description
This report examines the strategies and instruments that governments use to ensure compliance with pollution prevention and control regulations, particularly in the industrial sector.
Author: Richard S Collier
Publisher: Oxford University Press
ISBN: 0192603477
Category : Business & Economics
Languages : en
Pages : 368
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Book Description
Banks seem all too often involved in cases of misconduct, particularly involving the exploitation of tax systems. Banking on Failure explains why and how banks "game the system", accounting for these misconduct cases and analysing the wider implications for financial markets and tax systems. Banking on Failure: Cum-Ex and Why and How Banks Game the System explains why banks design and use structured products to exploit tax systems. It describes one of the biggest and most complex cases - the "cum-ex" scandal - in which hundreds of banks and funds from across the globe participated in the raid on the public exchequers of a number of countries, with losses in the tens of billions of euros. The book then draws on the significance of this case study, and what this tells us about modern banks and their interactions with tax systems. Banking on Failure demonstrates why the exploitation of tax systems by banks is an inevitable feature of the financial markets landscape, and suggests possible responses.
Author: Jeffrey Owens
Publisher: Kluwer Law International B.V.
ISBN: 9403531940
Category : Law
Languages : en
Pages : 152
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Book Description
National taxation authorities around the world are rapidly improving international cooperation, given the unprecedented triple impact of persistent revelations of large-scale corporate tax avoidance, the ever-increasing intricacies of digital cross-border transactions, and the unprecedented revenue deficits engendered by the COVID-19 pandemic. There is also a growing recognition that improving tax compliance needs to be reconciled with a legitimate desire on the part of businesses to have some certainty about their taxes. Cooperative compliance is one way to achieve that. This first analysis of the details of cooperative compliance programmes currently in operation describes tax control frameworks, suggests practical examples to assist practitioners in tax administrations and the private sector, and provides multiple perspectives on the design and legitimacy of such programmes. Drawing on detailed information contributed by tax practitioners and academics from a wide range of jurisdictions worldwide, the book identifies and explains certain crucial elements of successful programmes: the criteria for access to cooperative compliance (e.g., is the programme voluntary or mandatory? Is there a financial threshold? Will the criteria be publicly available?); model legislation that can facilitate the operation of such programmes (statutory provisions, administrative rules and procedures, etc.); the foundations for an international agreement on an audit assurance standard for tax control frameworks (including the role of the Organisation for Economic Co-operation and Development (OECD), the European Union (EU), and other international organizations); how to develop a methodology to measure the cost and benefits of cooperative compliance programmes; detailed case studies of existing compliance programmes in Australia, Austria, China, Germany, Italy, Poland, and Russia; and how to communicate a cooperative compliance programme to obtain trust from society. The analysis draws on two years of work led by WU Global Tax Policy Center (GTPC) at Vienna University of Economics and Business in cooperation with the International Chamber of Commerce (ICC) and the Commonwealth Association of Tax Administrators (CATA). The project brought together over two hundred people from 25 countries, including public officials, businesses, and academics. Tax certainty and predictability are key components for providing a tax environment that is conducive to cross-border trade and investment, and, in the long term, it is in the interest of both governments and businesses to minimize tax uncertainty as much as possible. This truly helpful book promises to pave the way to an internationally effective tax framework that will be welcomed by taxation authorities and practitioners worldwide.
Author: Christian Campbell
Publisher: Kluwer Law International B.V.
ISBN: 9403535318
Category : Law
Languages : en
Pages : 195
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Book Description
The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.
Author: United States. Congress. House. Committee on Appropriations. Subcommittee on Energy and Water Development
Publisher:
ISBN:
Category : Energy development
Languages : en
Pages : 1854
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Book Description
