Earnings and Profits

Earnings and Profits
Author: David Friedel
Publisher:
Total Pages:
Release: 2010-01
Genre: Corporations
ISBN: 9781558717404

"Discusses the principles and rules associated with earnings and profits (E & P)"--Portfolio description.

Tax Law Design and Drafting, Volume 1

Tax Law Design and Drafting, Volume 1
Author: Mr.Victor Thuronyi
Publisher: International Monetary Fund
Total Pages: 534
Release: 1996-08-23
Genre: Business & Economics
ISBN: 9781557755872

Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Taxation of Intercompany Dividends Under Tax Treaties and EU Law
Author: Guglielmo Maisto
Publisher: IBFD
Total Pages: 1093
Release: 2012
Genre: Corporations
ISBN: 9087221398

This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.