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Author:
Publisher:
ISBN: 9781910337486
Category :
Languages : en
Pages :
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Book Description
Author:
Publisher:
ISBN: 9781910337486
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author:
Publisher:
ISBN: 9781909790896
Category :
Languages : en
Pages :
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Book Description
Author: E. Gil García
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article analyses the reinforcement of the substance requirement in the current international standards. Due to globalization and complex business structures, countries have implemented measures to prevent base erosion and profit shifting (BEPS). Action Plans promoted by the OECD and EU are used globally to tackle harmful tax practices that allow multinational groups to carry out "aggressive" tax planning.
Author: I.J. Mosquera Valderrama
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The article provides an overview of the domestic anti-avoidance rules with specific reference to Brazil, Colombia, South Africa and Uruguay to evaluate the application of these rules to tackle aggressive tax planning. Secondly, it assesses whether or not the application of general anti-avoidance rules (GAARs) in these countries is consistent and clear (transparent) for the taxpayer. The main argument is that to tackle aggressive tax planning, countries should have GAARs in accordance with the standard of fiscal transparency as developed in this article (i.e. availability, clarity, simplicity and reliability). Furthermore, the relationship between the taxpayer and tax administration should be enhanced considering mutual trust, legitimate expectations and respect for the taxpayers' rights. This article provides recommendations to enhance the relationship between tax administration and taxpayers to facilitate a coordinated relationship. Such a coordinated relationship means, on the one hand, that the governments (tax administrations) are provided access to the information regarding the activities of the taxpayer; and, on the other hand, that taxpayers voluntarily disclose the structure and nature of the economic activities or businesses in the country.
Author: Kristina Murphy
Publisher:
ISBN: 9780642768247
Category : Tax planning
Languages : en
Pages :
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Book Description
Author: Edward Mendlowitz
Publisher: Simon & Schuster Books For Young Readers
ISBN:
Category : Business & Economics
Languages : en
Pages : 200
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Author:
Publisher:
ISBN: 9789276143178
Category :
Languages : en
Pages :
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Book Description
This Report analyses the EU's instruments to tackle aggressive tax planning and harmful tax practices. Based on desk research, interviews with stakeholders and expert assessments, it considers the coherence, relevance, and added value of the EU's approach. The instruments under analysis are found to be internally coherent and consistent with other EU policies and with the international tax agenda, in particular with the OECD/G20 BEPS framework. The Report also confirms the continued relevance of most of the original needs and problems addressed by the EU's initiatives in the field of tax avoidance. There is also EU added value in having common EU instruments in the field to bolster coordination and harmonise the implementation of tax measures. One cross-cutting issue identified is the impact of digitalisation on corporate taxation. Against this background, the Report outlines potential improvements to the EU tax strategy such as: making EU tax systems fit for the digital era; leading the international debate on tax avoidance; enabling capacity building in Member States and developing countries; strengthening tax good governance in third countries; ensuring a consistent approach at home and abroad; achieving a level playing field for all companies; and increasing tax certainty and legal certainty.
Author: Félix Daniel Martínez Laguna
Publisher: Kluwer Law International B.V.
ISBN: 9403510846
Category : Law
Languages : en
Pages : 685
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Book Description
Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Author: Irma Johanna Mosquera Valderrama
Publisher:
ISBN:
Category :
Languages : en
Pages : 16
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Book Description
The aim of this paper is to assess the feasibility to introduce the OECD-BEPS measures to deal with aggressive tax planning in South America and Sub-Saharan Africa. The BEPS and its Action Plan have been developed by the OECD following the G20 mandate and it provides new international tax standards to be applicable to all countries including OECD and non-OECD countries.This paper will provide a comparative analysis of the South America and the Sub-Saharan African region taking into account the country's economic development, tax administration capacity and resources, and the use (or not) of domestic laws and tax treaty rules to tackle aggressive tax planning. The South American and Sub-Saharan African regions have been chosen since they consist mostly of developing (non-OECD) countries. The comparative analysis of the exchange of best practices and challenges in these two regions will be useful for the OECD-BEPS Project and for the BEPS Multilateral Instrument that will be open for adoption by developing and developed countries.This paper is structured as follows: Section 1 contains a short introduction to the BEPS Actions dealing with aggressive tax planning and the discussions at OECD and UN level. Section 2 will provide the assessment of feasibility of the BEPS in South America and Sub-Saharan Africa. Finally, in Section 3, conclusions and recommendations will be presented.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91
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Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
