Report of Proceedings of the Tax Conference Convened by the Canadian Tax Foundation PDF Download
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Author: Canadian Tax Foundation
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1318
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Book Description
Author: Canadian Tax Foundation
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1318
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Book Description
Author: Canadian Tax Foundation
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1528
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Book Description
Author: Canadian Tax Foundation
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1078
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Book Description
Author: Canadian Tax Foundation
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1258
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Book Description
Author: Richard Krever
Publisher: Kluwer Law International B.V.
ISBN: 9403506156
Category : Law
Languages : en
Pages : 314
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Book Description
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
Author: Stefano Simontacchi
Publisher: Kluwer Law International B.V.
ISBN: 9041125493
Category : Law
Languages : en
Pages : 438
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Book Description
Increasing globalization and the related cross-border flows of capital resources has only increased interest in the taxation of transnational capital gains among practitioners and scholars. This is particularly true as it relates to investments in immovable property. As a consequence, Article 13 of the OECD Model Convention - covering capital gains - has emerged as one of the document's key provisions. Based on in-depth historical research, this book pays particular attention to the definition of capital gains falling within the scope of Article 13. It also thoroughly analyses the treaty regime applicable to gains derived from the alienation of both immovable property and shares of immovable property companies.
Author:
Publisher:
ISBN:
Category : Union catalogs
Languages : en
Pages : 620
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Book Description
Includes entries for maps and atlases.
Author: Staatsbibliothek der Stiftung Preussischer Kulturbesitz
Publisher:
ISBN:
Category : Periodicals
Languages : en
Pages : 1216
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Book Description
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:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 2312
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Book Description
