Tax Planning With Holding Companies Repatriation Of Us Profits From Europe PDF Download
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Author | : Rolf Eicke |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 526 |
Release | : 2009-01-01 |
Genre | : Law |
ISBN | : 9041127941 |
Download Tax Planning with Holding Companies - Repatriation of US Profits from Europe Book in PDF, ePub and Kindle
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Author | : Rolf Eicke |
Publisher | : |
Total Pages | : 520 |
Release | : 2008 |
Genre | : |
ISBN | : 9789041135155 |
Download Tax Planning with Holding Companies - Repatriation of US Profits from Europe Book in PDF, ePub and Kindle
When investments don't live up to their promise, the situation is typically due to several factors. In most cases, the key reasons are a combination of the place of investment, the product, and the selection of detrimental tax planning measures. Often, international tax planning tips the scales regarding the success of a U.S. investment in Europe. This timely book analyzes concepts and structures that can be used as a ""construction kit"" applying combinations of basic tools to meet the challenges of an ever-changing global tax environment. In the wake of globalization, a host of n.
Author | : Janice Eberly |
Publisher | : Brookings Institution Press |
Total Pages | : 484 |
Release | : 2017-10-10 |
Genre | : Business & Economics |
ISBN | : 081573252X |
Download Brookings Papers on Economic Activity: Spring 2017 Book in PDF, ePub and Kindle
Brookings Papers on Economic Activity (BPEA) provides academic and business economists, government officials, and members of the financial and business communities with timely research on current economic issues.
Author | : D.S. Smit |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 822 |
Release | : 2012-06-01 |
Genre | : Law |
ISBN | : 9041140743 |
Download EU Freedoms, Non-EU Countries and Company Taxation Book in PDF, ePub and Kindle
In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Author | : Leopoldo Parada |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 531 |
Release | : 2023-12-11 |
Genre | : Law |
ISBN | : 940354676X |
Download Double non-taxation and the use of hybrid entities Book in PDF, ePub and Kindle
The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
Author | : Claudio Cipollini |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 316 |
Release | : 2019-12-18 |
Genre | : Law |
ISBN | : 9403519231 |
Download Special Tax Zones and EU Law Book in PDF, ePub and Kindle
Economic recovery from the global financial crisis of 2007–2008 has been sketchy, with some areas within the European Union (EU) still trapped in seemingly irremediable industrial stagnation and job loss. EU institutions are called upon to provide concrete amelioration for these situations, through the design and implementation of effective tax policies in accordance with the fundamental principles of EU law. In this original, innovative book, the author presents a new and expanded view of how special tax zones (STZs) – areas of land where territorial advantages are granted on direct and/or indirect taxation – can deliver growth and mitigate economic and social emergency. Recognizing that, although a number of STZs within the EU have been established, there is still no systematic framework for them in the EU legal system, the author works out a comprehensive theory for STZs in the field of European tax law, dealing incisively with the interface of STZs with such essential legal and tax aspects as the following: customs union provisions; benefits on direct and indirect taxation; State-aid rules; free movement of persons; harmful tax competition; and role of EU social cohesion policies and their implementation. Furthermore, the author develops a new model of STZs for the most disadvantaged areas of the EU – the so-called Social Cohesion Zone – to respond decisively to issues of compatibility with such critical variables of EU law as those dealing with the outer limits set by State-aid rules and fundamental freedoms, clearly demonstrating the model’s practical viability. Detailed reviews of Member States’ practice in existing STZs and their tax regimes are thoroughly described so different variables can be compared. As a comprehensive description of the state of knowledge about STZs, including the relevant background and their current place in EU law, this book has no precedents and no peers. It allows practitioners, policymakers, and academics in tax law to fully understand the relationship between EU law, national legislation, and STZs, focusing on the possibility of reconciling the tax sovereignty of Member States with a supporting and coordinating role of the EU institutions. It will be warmly welcomed by the tax law community.
Author | : Maria Júlia Ildefonso Mendonça |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 381 |
Release | : 2023-01-22 |
Genre | : Law |
ISBN | : 9403503084 |
Download International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law Book in PDF, ePub and Kindle
The hurdles emerging from the parallel exercise of Member States’ tax sovereignty have been examined by the CJEU and intensely discussed by scholars. By uncovering a paradox in the CJEU’s case law, this groundbreaking book provides a constructive alternative to the deadlock created by the CJEU when ruling that international juridical double taxation, although constituting an obstacle to free movement, is not contrary to EU law. The book – the first in-depth treatment of this perspective – enables taxpayers facing international juridical double taxation to understand how their ability to pay is protected under EU law and the limitations that protection faces. Every aspect of the matter is rigorously examined, including the following: important differences between the traditional notion of double taxation and the current definition under Council Directive 2017/1852; legal means and methods designed to eliminate international juridical double taxation and the policies underlying them; freedoms of movement as prohibitions that limit the exercise of Member States’ taxing powers; consideration of expenses related to economic activity and personal and family circumstances; and in-depth discussion of taxation of income derived from source versus residence Member State. Throughout the book, the author refers to the case law of the CJEU on both international juridical double taxation and taxpayers’ ability to pay, as well as the relevant academic literature, allowing the reader to understand the current state of EU law on these matters and their relation. The author’s remarkable venture into this challenging field, with a deeply informed construction of instrumental categories and critical review of their content, culminates with a viable reformulation of the serious and growing problem of international juridical double taxation. The book will be welcomed by taxation professionals in practice, policymakers, and academia.
Author | : William J. Murphy |
Publisher | : John Wiley & Sons |
Total Pages | : 400 |
Release | : 2012-04-05 |
Genre | : Law |
ISBN | : 111822213X |
Download Patent Valuation Book in PDF, ePub and Kindle
A practical resource for valuing patents that is accessible tothe complete spectrum of decision makers in the patent process In today's economy, patents tend to be the most important of theintellectual property (IP) assets. It is often the ability tocreate, manage, defend, and extract value from patents that candistinguish competitive success and significant wealth creationfrom competitive failure and economic waste. PatentValuation enhances the utility and value of patents byproviding IP managers, IP creators, attorneys, and governmentofficials with a useable resource that allows them to use actual orimplied valuations when making patent-related decisions. Involves a combination of techniques for describing patentvaluation Includes descriptions of various topics, illustrative cases,step-by-step valuation techniques, user-friendly procedures andchecklists, and examples Serves as a useable resource that allows IP managers to useactual or implied valuations when making patent-relateddecisions One of the most fundamental premises of the book is that thesevaluation skills can be made accessible to each of the variousdecision makers in the patent process. Patent Valuationinvolves narrative descriptions of the various topics, illustrativecases, step-by-step valuation techniques, user-friendly proceduresand checklists, and an abundance of examples to demonstrate themore complex concepts.
Author | : Christoph Marchgraber |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 472 |
Release | : 2016-04-24 |
Genre | : Law |
ISBN | : 9041194118 |
Download Double (Non-)Taxation and EU Law Book in PDF, ePub and Kindle
Everywhere,new tax rules are under development to engage with the ever-increasing complexity and sophistication of aggressive tax planning and to reverse the tax base erosion it leads to. The most prominent initiative in this context is the Base Erosion and Profit Shifting (BEPS) project of the OECD. Although double non-taxation is among the main issues the BEPS project intends to address, this book shows that this phenomenon has not yet been fully understood. Focusing on the fundamental freedoms and the State aid rules of the EU, this book thoroughly explains the nature of double non-taxation from an EU law perspective, its relation to double taxation, and the impact of EU law on these phenomena. Among the issues dealt with in the course of the analysis are the following: – locating the gaps and inconsistencies among domestic tax systems exploited by taxpayers; – hybrid mismatch arrangements as a prime example of double non-taxation; – political efforts undertaken within the EU in order to address double taxation and double non-taxation; – double non-taxation in the European VAT system; – the convergence of the fundamental freedoms and the State aid rules; – the ECJ’s dilemma with regard to juridical double taxation; – the deviating approach with regard to economic double taxation; – the potential impact of the ECJ’s case law on the EU law compatibility of double non-taxation. The tax jurisprudence of the ECJ is referred to and comprehensively analysed throughout this whole book. A final chapter provides an outlook on possible developments in the future. By providing the first in-depth analysis of EU law’s impact on double non-taxation – and the double taxation relief standards with which it is intimately related – this book takes a giant step towards greater legal certainty in this challenging area of tax law. It will quickly take its place as a major practical analysis which benefits tax authorities, scholars, and tax practitioners across Europe and even beyond.
Author | : Werner Haslehner |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 328 |
Release | : 2018-12-20 |
Genre | : Law |
ISBN | : 9403501642 |
Download Time and Tax: Issues in International, EU, and Constitutional Law Book in PDF, ePub and Kindle
Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.