Corporate Taxation, Group Debt Funding and Base Erosion

Corporate Taxation, Group Debt Funding and Base Erosion
Author: Gianluigi Bizioli
Publisher: Kluwer Law International B.V.
Total Pages: 399
Release: 2020-02-07
Genre: Law
ISBN: 9403512318

The EU’s Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD’s Base Erosion and Profit Sharing project (BEPS) and the EU’s Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States—Germany, Italy, Spain and The Netherlands—as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.

Addressing Base Erosion and Profit Shifting

Addressing Base Erosion and Profit Shifting
Author: OECD
Publisher: OECD Publishing
Total Pages: 91
Release: 2013-02-12
Genre:
ISBN: 9264192743

This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report
Author: OCDE,
Publisher: OCDE
Total Pages: 70
Release: 2015
Genre: International business enterprises
ISBN: 9789264241466

This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

Electronic Invoicing in Latin America

Electronic Invoicing in Latin America
Author: Alberto Daniel Barreix
Publisher: Inter-American Development Bank
Total Pages: 75
Release: 2018-03-21
Genre: Business & Economics
ISBN:

The electronic invoicing (EI) of taxes is one of Latin America’s contributions to international taxation in support of the fight against evasion, global efforts towards tax transparency, and the digitization of tax administrations (TAs). Initially, EI was conceived as an instrument of documentary control over the invoicing process, so as to avert both the omission of sales and the inclusion of false purchases. The original idea was extended to other areas of tax control, such as payroll, goods in transit, and new services such as factoring. To some extent, EI can be regarded as the start of the process of digitizing the TAs in the broad sense. This publication addresses the pioneering experience of EI in Latin America, from its implementation to its extensions and impact on tax collection.

Action Plan on Base Erosion and Profit Shifting

Action Plan on Base Erosion and Profit Shifting
Author: OECD
Publisher: OECD Publishing
Total Pages: 44
Release: 2013-07-19
Genre:
ISBN: 9264202714

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Tax Sovereignty in the BEPS Era

Tax Sovereignty in the BEPS Era
Author: Sergio André Rocha
Publisher: Kluwer Law International B.V.
Total Pages: 378
Release: 2016-04-24
Genre: Law
ISBN: 9041167080

The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

Latin American Economic Outlook 2021 Working Together for a Better Recovery

Latin American Economic Outlook 2021 Working Together for a Better Recovery
Author: OECD
Publisher: OECD Publishing
Total Pages: 274
Release: 2021-12-02
Genre:
ISBN: 9264682317

The Latin American Economic Outlook 2021: Working Together for a Better Recovery aims to analyse and provide policy recommendations for a strong, inclusive and environmentally sustainable recovery in the region. The report explores policy actions to improve social protection mechanisms and increase social inclusion, foster regional integration and strengthen industrial strategies, and rethink the social contract to restore trust and empower citizens at all stages of the policy‐making process.

Foreign Direct Investment in Latin America and the Caribbean 2021

Foreign Direct Investment in Latin America and the Caribbean 2021
Author: UNITED NATIONS ECONOMIC COMMISSION FOR LATIN AMERICA AND THE. CARIBBEAN
Publisher:
Total Pages: 170
Release: 2021-11
Genre:
ISBN: 9789211220735

This document examines the global and regional evolution of Foreign Direct Investment (FDI) and offers recommendations so these flows can contribute to the region's productive development processes.

World Development Report 2019

World Development Report 2019
Author: World Bank
Publisher: World Bank Publications
Total Pages: 201
Release: 2018-10-31
Genre: Business & Economics
ISBN: 1464813566

Work is constantly reshaped by technological progress. New ways of production are adopted, markets expand, and societies evolve. But some changes provoke more attention than others, in part due to the vast uncertainty involved in making predictions about the future. The 2019 World Development Report will study how the nature of work is changing as a result of advances in technology today. Technological progress disrupts existing systems. A new social contract is needed to smooth the transition and guard against rising inequality. Significant investments in human capital throughout a person’s lifecycle are vital to this effort. If workers are to stay competitive against machines they need to train or retool existing skills. A social protection system that includes a minimum basic level of protection for workers and citizens can complement new forms of employment. Improved private sector policies to encourage startup activity and competition can help countries compete in the digital age. Governments also need to ensure that firms pay their fair share of taxes, in part to fund this new social contract. The 2019 World Development Report presents an analysis of these issues based upon the available evidence.

Crimes Committed by Terrorist Groups

Crimes Committed by Terrorist Groups
Author: Mark S. Hamm
Publisher: DIANE Publishing
Total Pages: 258
Release: 2011
Genre: Political Science
ISBN: 1437929591

This is a print on demand edition of a hard to find publication. Examines terrorists¿ involvement in a variety of crimes ranging from motor vehicle violations, immigration fraud, and mfg. illegal firearms to counterfeiting, armed bank robbery, and smuggling weapons of mass destruction. There are 3 parts: (1) Compares the criminality of internat. jihad groups with domestic right-wing groups. (2) Six case studies of crimes includes trial transcripts, official reports, previous scholarship, and interviews with law enforce. officials and former terrorists are used to explore skills that made crimes possible; or events and lack of skill that the prevented crimes. Includes brief bio. of the terrorists along with descriptions of their org., strategies, and plots. (3) Analysis of the themes in closing arguments of the transcripts in Part 2. Illus.