Author: Peter Antony Wilson
Publisher: Kluwer Law International B.V.
Published: 2016-04-24
Total Pages: 384
ISBN-13: 9041194363
DOWNLOAD EBOOK →With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Author: A. J. Easson
Publisher:
Published: 1991
Total Pages: 60
ISBN-13:
DOWNLOAD EBOOK →The book looks critically at systems of international taxation and points out defects which could be rectified. It also looks ahead at possible directions for international taxation reform in preparation for the 21st century. It deals with: the search for an optimal system of international taxation; foreign direct investment and the multinational enterprise; neutrality and the efficient allocation of resources; inter-nation equity; transfer pricing; the treatment of intra-group payments, implementation.
Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
Published: 1962
Total Pages: 1532
ISBN-13:
DOWNLOAD EBOOK →Author: Mark Brabazon
Publisher: Cambridge University Press
Published: 2019-05-02
Total Pages: 417
ISBN-13: 1108492258
DOWNLOAD EBOOK →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: United States. Bureau of Internal Revenue
Publisher:
Published: 1925
Total Pages: 822
ISBN-13:
DOWNLOAD EBOOK →Author: Helmut Loukota
Publisher: Kluwer Law International B.V.
Published: 1998-04-22
Total Pages: 266
ISBN-13: 9041107045
DOWNLOAD EBOOK →The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
Author: Andrew Lymer
Publisher: Springer Science & Business Media
Published: 2012-12-06
Total Pages: 319
ISBN-13: 1461510716
DOWNLOAD EBOOK →International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.