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Switzerland in International Tax Law

Switzerland in International Tax Law
Author: Xavier Oberson
Publisher: IBFD
Total Pages: 457
Release: 2011
Genre: Double taxation
ISBN: 9087220987

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"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).


Taxation in Switzerland

Taxation in Switzerland
Author: Harvard Law School. International Tax Program
Publisher:
Total Pages: 1456
Release: 1976
Genre: Taxation
ISBN:

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International Tax Planning and Prevention of Abuse

International Tax Planning and Prevention of Abuse
Author: Luc De Broe
Publisher: IBFD
Total Pages: 1146
Release: 2008
Genre: Corporations
ISBN: 9087220359

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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.


International Tax Policy

International Tax Policy
Author: Tsilly Dagan
Publisher: Cambridge University Press
Total Pages: 263
Release: 2017-12-14
Genre: Business & Economics
ISBN: 1107112109

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Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.


Residence of Individuals Under Tax Treaties and EC Law

Residence of Individuals Under Tax Treaties and EC Law
Author: Guglielmo Maisto
Publisher: IBFD
Total Pages: 709
Release: 2010
Genre: Domicile in taxation
ISBN: 9087220758

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This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.


Tax Laws of the World

Tax Laws of the World
Author: Switzerland
Publisher:
Total Pages:
Release: 1975
Genre: Income tax
ISBN:

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Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law

Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law
Author: Guglielmo Maisto (jurist.)
Publisher: IBFD
Total Pages: 375
Release: 2005
Genre: Law
ISBN: 9076078823

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The book identifies linguistic issues arising in bilateral income tax conventions and presents an in-dept analysis of tax treaty policies on multilingualism and the administrative practice and case law on the issues raised by the translation of treaties. Individual country surveys discuss the use of legal concepts, including those that do not exist in the legal system of one of the two contracting states and the way such concepts should be interpreted in such state (e.g. trust). Further, the use of concepts in one state that are similar but not identical to a treaty concept that is well known only in the other state (e.g. droit d'auteur vs copyright) are presented. The book also includes special reports on multilingual issues under both art. 33 of the Vienna Convention and art. 3(2) of the OECD Model Convention and Commentaries. Finally, a specific chapter is devoted to the EU law aspects and a review of the jurisprudence of the European Court of Justice (ECJ).


Chinese Tax Law and International Treaties

Chinese Tax Law and International Treaties
Author: Lorenzo Riccardi
Publisher: Springer Science & Business Media
Total Pages: 278
Release: 2013-05-30
Genre: Law
ISBN: 3319002759

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The People’s Republic of China’s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation’s rise to the world’s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China’s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China’s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China’s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis. Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.