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Author: Nathalie Bravo
Publisher: Linde Verlag GmbH
ISBN: 3709411580
Category : Law
Languages : en
Pages : 536
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Book Description
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author: Nathalie Bravo
Publisher: Linde Verlag GmbH
ISBN: 3709411580
Category : Law
Languages : en
Pages : 536
Get Book Here
Book Description
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author: Erik Pinetz
Publisher: Linde Verlag GmbH
ISBN: 3709408822
Category : Law
Languages : en
Pages : 454
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Book Description
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
Author: Organisation for Economic Co-operation and Development
Publisher: OECD
ISBN:
Category : Business & Economics
Languages : en
Pages : 172
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Book Description
A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Author: Elena G. Popkova
Publisher: Springer Nature
ISBN: 3030479455
Category : Technology & Engineering
Languages : en
Pages : 1763
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Book Description
This book presents a system view of the digital scientific and technological revolution, including its genesis and prerequisites, current trends, as well as current and potential issues and future prospects. It gathers selected research papers presented at the 12th International Scientific and Practical Conference, organized by the Institute of Scientific Communications. The conference “Artificial Intelligence: Anthropogenic Nature vs. Social Origin” took place on December 5–7, 2019 in Krasnoyarsk, Russia. The book is intended for academic researchers and independent experts studying the social and human aspects of the Fourth Industrial Revolution and the associated transition to the digital economy and Industry 4.0, as well as the creators of the legal framework for this process and its participants – entrepreneurs, managers, employees and consumers. It covers a variety of topics, including “intelligent” technologies and artificial intelligence, the digital economy, the social environment of the Fourth Industrial Revolution and its consequences for humans, the regulatory framework of the Fourth Industrial Revolution, and the “green” consequences, prospects and financing of the Fourth Industrial Revolution.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241159
Category :
Languages : en
Pages : 75
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Author: Reuven S. Avi-Yonah
Publisher: Cambridge University Press
ISBN: 9780521618014
Category : Law
Languages : en
Pages : 224
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Book Description
This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
Author: Michael Lang
Publisher:
ISBN: 9789087225674
Category :
Languages : en
Pages :
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Book Description
Author: International Monetary Fund
Publisher: International Monetary Fund
ISBN: 1498344658
Category : Business & Economics
Languages : en
Pages : 257
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Book Description
This paper explores how fiscal policy can affect medium- to long-term growth. It identifies the main channels through which fiscal policy can influence growth and distills practical lessons for policymakers. The particular mix of policy measures, however, will depend on country-specific conditions, capacities, and preferences. The paper draws on the Fund’s extensive technical assistance on fiscal reforms as well as several analytical studies, including a novel approach for country studies, a statistical analysis of growth accelerations following fiscal reforms, and simulations of an endogenous growth model.
Author: International Monetary Fund
Publisher: International Monetary Fund
ISBN: 1498344895
Category : Business & Economics
Languages : en
Pages : 81
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Book Description
This paper addresses core challenges that all tax administrations face in dealing with noncompliance—which are now receiving renewed attention. Long a priority in developing countries, assuring strong compliance has acquired greater priority in countries facing intensified revenue needs, and is critical for fairness and statebuilding. Series: Policy Papers
Author: OECD
Publisher: OECD Publishing
ISBN: 9264338462
Category :
Languages : en
Pages : 125
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Book Description
This is the fifth edition of Tax Policy Reforms: OECD and Selected Partner Economies, an annual publication that provides comparative information on tax reforms across countries and tracks tax policy developments over time. The report covers the latest tax policy reforms in all OECD countries, as well as in Argentina, China, Indonesia and South Africa.
