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Author: Johann Müller (podatki)
Publisher: IBFD
ISBN: 9087220243
Category : Business enterprises, Foreign
Languages : en
Pages : 417
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Book Description
This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
Author: Johann Müller (podatki)
Publisher: IBFD
ISBN: 9087220243
Category : Business enterprises, Foreign
Languages : en
Pages : 417
Get Book Here
Book Description
This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
Author: Luc De Broe
Publisher: IBFD
ISBN: 9087220359
Category : Corporations
Languages : en
Pages : 1146
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Book Description
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Author: Adrian Ogley
Publisher: International Information Services Incorporated
ISBN: 9780952044208
Category : Business & Economics
Languages : en
Pages : 186
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Book Description
This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.
Author: Mark Brabazon
Publisher: Cambridge University Press
ISBN: 1108492258
Category : Law
Languages : en
Pages : 417
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Book Description
This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
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: Guglielmo Maisto
Publisher: IBFD
ISBN: 9076078920
Category : Double taxation
Languages : en
Pages : 433
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Book Description
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Author: Stef Weeghel
Publisher: Kluwer Law International B.V.
ISBN: 9041107371
Category : Business & Economics
Languages : en
Pages : 302
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Book Description
"With particular reference to the Netherlands and the United States."--T.p.
Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 148436399X
Category : Business & Economics
Languages : en
Pages : 45
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Book Description
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087220707
Category : Business enterprises
Languages : en
Pages : 504
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Book Description
In response to a number of large corporate failures, risk management has recently become a major consideration for most organizations. At the same time, taxation has been recognized as an area having its own unique risk profiles. This book provides a practical guide for those working in today's ever-changing corporate environment. It contains an introduction to tax risk management and discussions on the tax control framework that allow corporate tax departments to identify and manage companies' tax-related risks. The book also includes country chapters, which provide practical examples of the development and application of tax control frameworks.
Author: Werner C. Haslehner
Publisher:
ISBN: 9789087226893
Category : Commercial law
Languages : en
Pages :
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Book Description
This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
