Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries

Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries
Author: United Nations Publications
Publisher:
Total Pages: 158
Release: 2014
Genre: Business & Economics
ISBN:

Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.

International Tax Policy and Double Tax Treaties

International Tax Policy and Double Tax Treaties
Author: Kevin Holmes
Publisher: IBFD
Total Pages: 433
Release: 2007
Genre: Double taxation
ISBN: 9087220235

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

The Effect of Treaties on Foreign Direct Investment

The Effect of Treaties on Foreign Direct Investment
Author: Karl P Sauvant
Publisher: Oxford University Press
Total Pages: 795
Release: 2009-03-27
Genre: Law
ISBN: 0199745188

Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.

Fiscal Regimes for Extractive Industries—Design and Implementation

Fiscal Regimes for Extractive Industries—Design and Implementation
Author: International Monetary Fund. Fiscal Affairs Dept.
Publisher: International Monetary Fund
Total Pages: 82
Release: 2012-08-16
Genre: Business & Economics
ISBN: 1498340067

Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Interpretation and Application of Tax Treaties in North America

Interpretation and Application of Tax Treaties in North America
Author: Juan Angel Becerra
Publisher: IBFD
Total Pages: 299
Release: 2007
Genre: Canada
ISBN: 9087220197

This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Sociétés Transnationales

Sociétés Transnationales
Author: United Nations Conference on Trade and Development. Programme on Transnational Corporations
Publisher: New York : United Nations
Total Pages: 744
Release: 1993
Genre: Business & Economics
ISBN:

Policy Framework for Investment

Policy Framework for Investment
Author: OECD
Publisher: OECD Publishing
Total Pages: 72
Release: 2006-05-11
Genre:
ISBN: 9264018476

Drawing on good practices from OECD and non-OECD countries, the Framework proposes a set of questions for governments to consider in ten policy fields as critically important for the quality of a country’s environment for investment.

Preventing Treaty Abuse

Preventing Treaty Abuse
Author: Daniel Blum
Publisher: Linde Verlag GmbH
Total Pages: 571
Release: 2016-09-19
Genre: Law
ISBN: 3709408377

Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.

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.