Taxation Of Income From Domestic And Cross Border Collective Investment
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Author | : Andreas Oestreicher |
Publisher | : Springer Science & Business Media |
Total Pages | : 170 |
Release | : 2013-07-30 |
Genre | : Law |
ISBN | : 3319004492 |
The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 172 |
Release | : 1999-05-04 |
Genre | : |
ISBN | : 9264172882 |
This book analyses the taxation of cross-border portfolio investments by means of collective investment institutions. Possible tax distortions specific to the area of collective investment institutions are identified for a representative group of OECD countries.
Author | : |
Publisher | : Org. for Economic Cooperation & Development |
Total Pages | : 184 |
Release | : 1999 |
Genre | : Business & Economics |
ISBN | : |
The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institution
Author | : Tomi Viitala |
Publisher | : IBFD |
Total Pages | : 427 |
Release | : 2005 |
Genre | : Capital gains tax |
ISBN | : 9076078750 |
The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Author | : Michael Honiball |
Publisher | : Siber Ink |
Total Pages | : 908 |
Release | : 2011-03-15 |
Genre | : Business & Economics |
ISBN | : 1920025774 |
This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.
Author | : John Prebble |
Publisher | : |
Total Pages | : 216 |
Release | : 2006 |
Genre | : Biography & Autobiography |
ISBN | : |
An international panel of experts address the design and operation of offshore investment fund regimes. The book is comparative, dealing with topics issue-by-issue rather than country-by-country. (Legal Reference/Law)
Author | : United States. Congress. Joint Committee on Internal Revenue Taxation |
Publisher | : |
Total Pages | : 40 |
Release | : 1975 |
Genre | : Income tax |
ISBN | : |
Author | : Klaus Vogel |
Publisher | : Springer |
Total Pages | : 62 |
Release | : 1994-01-11 |
Genre | : Business & Economics |
ISBN | : |
This study discusses the issues involved in making an informed choice between the source principle and the domicile principle as the basis for allocating the corporate profits base.
Author | : Gary Clyde Hufbauer |
Publisher | : Peterson Institute |
Total Pages | : 340 |
Release | : 2007 |
Genre | : Corporations, Foreign |
ISBN | : 0881325732 |
Author | : John Whalley |
Publisher | : |
Total Pages | : 44 |
Release | : 2001 |
Genre | : Capital movements |
ISBN | : |
I discuss the tax treatment of transborder capital income, focussing on prevailing arrangements rather than de novo design of optimal tax arrangements. These comprise unilateral reliefs from double taxation under credit or exemption systems, and treaty reliefs (largely following the OECD model treaty) which jointly lower withholding tax rates on interest, dividends, and royalties in both host and source countries. I suggest that these arrangements involve both seemingly non-strategic unilateral actions and cooperative arrangements which are difficult to reconcile both with tax competition literature and with national interest. I pose four puzzles in this regard. The first is that from a national welfare point of view, the unilateral reliefs in use seem inferior to no relief since with competitive markets investors equate the private return on investments at home and abroad, while tax revenues largely accrue to the foreign government. Private returns are equated, but national returns are not. The second is that tax treaties only have lump sum effects between national governments if the more common credit arrangements of unilateral reliefs apply and if tax rates are similar in host and source countries (approximately the OECD situation). This raises the issue of why governments negotiate them. The third is the sharp contrast to international treaty arrangements for goods flows under the WTO; and the fourth is the absence of side payments in tax treaties. The picture emerging is that making sense of present arrangements from a national welfare point of view and in terms of efficient instrument design seems difficult. The gap relative to optimal tax considerations also seems large.