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Author: Charles Haccius
Publisher: IBFD
ISBN: 9076078742
Category : Double taxation
Languages : en
Pages : 1399
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Book Description
Revised and updated edition providing the introduction to Irish tax legislation, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Follows practical discussion of Ireland's tax breaks, beginning with a discussion of the circumstances in which a company resident or carrying on business in Ireland qualifies for the 12.5% rate of corporation tax, and continuing with the issues of the tax efficient establishment and financing of a trading presence in Ireland, whether through a subsidiary or a permanent establishment or both. Possible tax planning opportunities are then discussed, both long standing tax breaks such as relief for artists and inventors, forestry, bloodstock and foreign domiciliaries, and opportunities such as those arising from the exercise of an employment in Ireland and the employment of crew members employed on ships or aircraft by an Irish resident company. The book also discusses transfer pricing and anti-avoidance provisions both in the Irish domestic tax legislation and in tax treaties.
Author: Charles Haccius
Publisher: IBFD
ISBN: 9076078742
Category : Double taxation
Languages : en
Pages : 1399
Get Book Here
Book Description
Revised and updated edition providing the introduction to Irish tax legislation, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Follows practical discussion of Ireland's tax breaks, beginning with a discussion of the circumstances in which a company resident or carrying on business in Ireland qualifies for the 12.5% rate of corporation tax, and continuing with the issues of the tax efficient establishment and financing of a trading presence in Ireland, whether through a subsidiary or a permanent establishment or both. Possible tax planning opportunities are then discussed, both long standing tax breaks such as relief for artists and inventors, forestry, bloodstock and foreign domiciliaries, and opportunities such as those arising from the exercise of an employment in Ireland and the employment of crew members employed on ships or aircraft by an Irish resident company. The book also discusses transfer pricing and anti-avoidance provisions both in the Irish domestic tax legislation and in tax treaties.
Author: Alan Moore
Publisher: Tax World Ltd
ISBN: 1902065751
Category : Business & Economics
Languages : en
Pages : 374
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Book Description
An easy to read guide to the Irish tax system for business owners, professionals and employees. The only guide that shows you, in simple steps, how to reduce your tax bill - covering income tax, PRSI, USC, corporation tax, capital gains tax, stamp duties, with specialist chapters on farming, marital breakdown, tax planning, and pension planning.
Author: Kevin Holmes
Publisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
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Book Description
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
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’.
Author: Lynne Oats
Publisher: Bloomsbury Publishing
ISBN: 1526519577
Category : Business & Economics
Languages : en
Pages : 709
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Book Description
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Author:
Publisher: Bloomsbury Publishing
ISBN: 1780436777
Category : Law
Languages : en
Pages : 829
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Book Description
This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277
Author: Emanuel Kopp
Publisher: International Monetary Fund
ISBN: 1498317049
Category : Business & Economics
Languages : en
Pages : 37
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Book Description
There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
Author: William C. Gifford
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 760
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Book Description
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: Joseph M. Dodge
Publisher: Aspen Publishing
ISBN: 1454860421
Category : Law
Languages : en
Pages : 679
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Book Description
This book deals with the federal income tax as it bears on gratuitous transfers and with the federal wealth transfer taxes. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. Features: Emphasis on text, statutes, and regulations, rather than cases (especially cases that involve routine application of law to facts) "Building block" organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students High-profile authorship in Joseph M. Dodge (a highly regarded tax specialist), Wendy C. Gerzog, and Bridget J. Crawford (both well-established in the field) The book reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. For example, special valuation rules are treated as basic, as opposed to being just "tacked on" as other books treat them. More emphasis on valuation and use of FLPs than in other books. Valuation is introduced early on and integrated with other material Integration of related income tax materials, including income taxation of estates and trusts Relation of tax doctrine to tax planning strategies Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems
