United Nations Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries PDF Download
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Author: United Nations Publications
Publisher:
ISBN: 9789211591231
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
The Handbook highlights the issues developing countries should bear in mind when negotiating new contracts for the exploration and exploitation of natural and mineral resources within their territories. It covers the following topics: tax treaty issues; permanent establishment issues; indirect transfer of assets; transfer pricing issues; tax treatment of decommissioning; the government's fiscal take; tax aspects of negotiation and renegotiation of contracts; and value added taxation issues.
Author: United Nations Publications
Publisher:
ISBN: 9789211591231
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
The Handbook highlights the issues developing countries should bear in mind when negotiating new contracts for the exploration and exploitation of natural and mineral resources within their territories. It covers the following topics: tax treaty issues; permanent establishment issues; indirect transfer of assets; transfer pricing issues; tax treatment of decommissioning; the government's fiscal take; tax aspects of negotiation and renegotiation of contracts; and value added taxation issues.
Author: Tony Addison
Publisher: Oxford University Press
ISBN: 0198817363
Category : Business & Economics
Languages : en
Pages : 766
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Book Description
"A study prepared by the United Nations University World Institute for Development Economics Research (UNU-WIDER)".
Author: Anna Binder
Publisher: Linde Verlag GmbH
ISBN: 3709410401
Category : Law
Languages : en
Pages : 537
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Book Description
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.
Author:
Publisher: Oxford University Press
ISBN: 0192872346
Category :
Languages : en
Pages : 241
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Book Description
Author: Benjamin Daßler
Publisher: Oxford University Press
ISBN: 0198881924
Category : Political Science
Languages : en
Pages : 305
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Book Description
The implicit topology of international institutional complexes varies greatly across policy areas. In some areas, the lion's share of everyday policy cooperation is shaped by a single institution with alternative and more regional institutions operating in its shadow. In other policy fields, institutional structures appear to be different, seeing a range of non-hierarchical, decentralized, alternative institutions. The Institutional Topology of International Regime Complexes: Mapping Inter-Institutional Structures in Global Governance provides a systematic conceptualization and explanation of the evolution of these varying institutional topologies underlying regime complexes across five issue areas of Global Governance: Intellectual Property Protection, Tax Avoidance, Financial Stability, Development Aid, and Energy Governance. By providing an empirically grounded, network-based conceptualization and mapping of institutional topologies, as well as a theoretical explanation for their variation across policy space and time, the book offers a comprehensive analysis of both the empirical manifestation of inter-institutional structures across various policy fields of Global Governance and the issue specific factors that shape the varying institutional trajectories spurring (de-) centralization. Daßler combines quantitative network analyses with qualitative case studies to trace institutional decentralization processes across five highly relevant issue areas of Global Governance. This volume shows how the nature of issue-specific cooperation problems translates into disparate structures among multilateral institutions occupying the same regime complex. In light of growing concerns about the future trajectories of Global Governance in times of heightened geopolitical tensions, Daßler offers a fresh perspective to comparatively capture the profoundly varying institutional landscapes across different issue areas and their associated challenges and benefits of multilateral cooperation. Transformations in Governance is a major academic book series from Oxford University Press. It is designed to accommodate the impressive growth of research in comparative politics, international relations, public policy, federalism, and environmental and urban studies concerned with the dispersion of authority from central states to supranational institutions, subnational governments, and public-private networks. It brings together work that advances our understanding of the organization, causes, and consequences of multilevel and complex governance. The series is selective, containing annually a small number of books of exceptionally high quality by leading and emerging scholars. The series is edited by Liesbet Hooghe and Gary Marks of the University of North Carolina, Chapel Hill, and Walter Mattli of the University of Oxford.
Author:
Publisher:
ISBN:
Category : Electronic journals
Languages : en
Pages : 458
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Book Description
Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 940352393X
Category : Law
Languages : en
Pages : 326
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Book Description
Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Author: Lynne Oats
Publisher: Bloomsbury Publishing
ISBN: 1526519569
Category : Business & Economics
Languages : en
Pages : 773
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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: Allison Christians
Publisher: Oxford University Press
ISBN: 0192664859
Category : Law
Languages : en
Pages : 209
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Book Description
The way that nation states design their tax systems impacts the sharing of resources and wealth within and across societies. To date, wealthy countries have made tax policy design and coordination choices which allow them to claim more than they are justifiably entitled to from the global economy. In Tax Cooperation in an Unjust World, Allison Christians and Laurens van Apeldoorn show how this presently accepted reality both facilitates and feeds off continued human suffering, and therefore violates conceptions of international distributive justice. They examine two principles that govern tax cooperation across states, and explain how the current international tax order impedes their realization. They then show how states could work toward fulfilling the principles and building a fairer international tax system via incremental yet effective adaptation of key international tax norms and rules.
Author: Christian Knotzer
Publisher: Kluwer Law International B.V.
ISBN: 940352488X
Category : Law
Languages : en
Pages : 551
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Book Description
This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.
