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| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 75 |
| Release | : 2015-06-29 |
| Genre | : |
| ISBN | : 9264238107 |
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 302 |
| Release | : 2021-04-01 |
| Genre | : |
| ISBN | : 9264950982 |
The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 266 |
| Release | : 2019-02-14 |
| Genre | : |
| ISBN | : 9264312382 |
BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all Inclusive Framework members have committed to implement.This report reflects the outcome of the first peer review of the implementation ...
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 658 |
| Release | : 2017-12-18 |
| Genre | : |
| ISBN | : 9264287957 |
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
| Author | : Michael Lang |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 360 |
| Release | : 2018-11-27 |
| Genre | : Law |
| ISBN | : 9403501219 |
Since its announcement in 2013, the Belt and Road Initiative (BRI), also known as the New Silk Road, has gradually gained international recognition. The project requires not only extensive investment in infrastructure and transportation but also an acceleration of the internationalization of multinationals and supply chains in Belt and Road countries. The project will, hopefully, lead governments and businesses in countries along the Belt and Road to compete, adopt best practices and improve transparency. The BRI marks a national push by China to increase economic links to Southeast Asia, Central Asia, Russia, the Baltic region (Central and Eastern Europe), Africa and Latin America, which will have major consequences for the way that tax systems interact. Emerging from the research conducted by the WU Global Tax Policy Center in cooperation with several Chinese universities, this book offers fourteen policy-relevant research papers prepared by international experts on the following issues: • The New Silk Road: Will Tax Be a Facilitator or a Barrier? • Neo-BEPS: China’s Prescription for International Tax Reform Embodying the Rationality of the Belt & Road Initiative; • International Taxation Coordination under China’s Belt and Road Strategy; • Tax Issues in the Main Belt and Road Countries and Industries of China’s Outward Foreign Direct Investment; • Preferential Arrangements under Chinese Tax Treaties with Belt and Road Countries and Disputes Regarding Their Applicability; • Tax Planning by Going-Global Enterprises for Cross-Border Earnings: Observations Based on Belt and Road Countries; • International Taxation Issues under the Belt and Road Initiative: Corporate Income Tax Laws and Tax Treaties; • Financial and Tax Operations in the Five Central Asian Countries; • The Role of Border-Crossing Procedures in the Transportation of Goods along the New Silk Road; • Transfer Pricing Issues Related to the Belt and Road Initiative; • Tax Treaties between Belt and Road Countries; • VAT Challenges in the Belt and Road Initiative; • Global Tax Policy Post-BEPS and the Perils of the Silk Road; and • Creating a Positive Tax Climate for Complex Multijurisdictional Investment Projects. Outcomes presented in the book consist of findings presented during Tax Policy Forum on the Belt and Road Initiative held on 12–13 June 2017 in Beijing, jointly organized with Peking University Tax Law Center and the Central University of Finance and Economics, Beijing. These papers also formed the basis for input by WU Global Tax Policy Center at the first meeting of The Belt and Road Initiative Tax Cooperation Conference (BRITCC) held in Astana on 14–16 May 2018, in which it was agreed to establish a permanent forum to examine the tax issues that arise from the BRI. The WU Global Tax Policy Center will continue to provide inputs to this forum.
| Author | : Erik Pinetz |
| Publisher | : Linde Verlag GmbH |
| Total Pages | : 454 |
| Release | : 2017-08-30 |
| Genre | : Law |
| ISBN | : 3709408822 |
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 | : Georg Kofler et al. |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 492 |
| Release | : 2024-06-24 |
| Genre | : Law |
| ISBN | : 9403526688 |
As the struggle to combat tax abuse and tax avoidance gains momentum, ways of making a tax jurisdiction ‘manipulation-proof’ continue to proliferate, from new or revised provisions in model tax treaties to a dramatic increase in the number and variety of anti-abuse and anti-avoidance rules at all levels of government. These measures interact with national tax systems, general anti-abuse clauses and tax treaties. The conflicts and other legal difficulties that inevitably result deserve intensive scrutiny. This book provides an in-depth analysis of current issues concerning the relations of various anti-abuse rules to each other and their impact on the application of tax treaties. The topics include the following: domestic general anti-avoidance rules (GAARs); domestic specific anti-avoidance rules (SAARs) (including controlled foreign company rules); minimum holding periods; indirect transfers of immovable property, shares, and rights; limitation on benefits; residence criteria in tax treaties; tax treatment of sportspersons and entertainers; the principal purpose test of Article 29 (9) OECD Model (2017); and influence of European Union Law on tax treaty abuse. The chapters are revised and expanded versions of papers presented at the 30th Viennese Symposium on International Tax Law held on 12 June 2023 at Vienna University of Economics and Business. Each author offers an in-depth analysis of a particular topic, drawing on the most recent scientific research. This is the only book available to offer such a wide-ranging, detailed, and practical analysis of how the full range of anti-abuse rules interacts with tax treaties. It will prove of immeasurable value to practitioners and law firms active in tax planning, tax consultants, academics and researchers in international tax law and counsel for companies involved in international business.
| Author | : Angelika Meindl-Ringler |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 458 |
| Release | : 2016-06-07 |
| Genre | : Law |
| ISBN | : 9041168397 |
In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
| Author | : Daniel Blum |
| Publisher | : Linde Verlag GmbH |
| Total Pages | : 571 |
| Release | : 2016-09-19 |
| Genre | : Law |
| ISBN | : 3709408377 |
Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 202 |
| Release | : 2014-09-16 |
| Genre | : |
| ISBN | : 9264218785 |
This book presents an analysis of the challenges the spread of the digital economy poses for international taxation.
