Advance Ruling:Practice and Legality

Advance Ruling:Practice and Legality

Author: International Fiscal Association Staff

Publisher: Springer

Published: 1994-07-11

Total Pages: 0

ISBN-13: 9789065448439

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Proceedings of a seminar held in Cancún, Mexico, in 1992 during the 46th congress of the International Fiscal Association.


Advance Tax Rulings and Principles of Law

Advance Tax Rulings and Principles of Law

Author: Carlo Romano (juriste).)

Publisher: IBFD

Published: 2002

Total Pages: 579

ISBN-13: 9076078491

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Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.


Introducing an Advance Tax Ruling (ATR) Regime

Introducing an Advance Tax Ruling (ATR) Regime

Author: Mr.Christophe Waerzeggers

Publisher: International Monetary Fund

Published: 2016-05-31

Total Pages: 14

ISBN-13: 1484375041

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Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.


Model Rules of Professional Conduct

Model Rules of Professional Conduct

Author: American Bar Association. House of Delegates

Publisher: American Bar Association

Published: 2007

Total Pages: 216

ISBN-13: 9781590318737

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The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.


Austrian Advance Rulings Measures and their Compatibility with EU and OECD Provisions against Harmful Tax Competition

Austrian Advance Rulings Measures and their Compatibility with EU and OECD Provisions against Harmful Tax Competition

Author: Christina Gruber

Publisher: diplom.de

Published: 2003-07-29

Total Pages: 115

ISBN-13: 3832470557

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Inhaltsangabe:Abstract: This paper is intended to give an overview over Austrian advance rulings in an international context. In order to be able to outline the Austrian rulings practice and provisions that constitute a legal basis for advance rulings -- since in Austria rulings are not based upon one single law or provision but on many -- the term advance ruling will be defined as well and its meaning in international tax practice will be described. Moreover, this paper is intended to examine Austrian rulings measures in the light of the EU and OECD provisions against harmful tax competition, as well as under the state aid provisions of the EC Treaty. It is structured as follows: In the first part, the provisions of the EU (Code of Conduct of Business Taxation) and OECD (report on harmful tax competition) against harmful tax competition as well as the state aid provisions are described and the discussion, as to whether provisions against harmful tax competition are necessary at all, is outlined briefly. Then, international rulings practice is explained. Finally and essentially, Austrian rulings provisions are described in detail and assessed according to the criteria to identify harmful tax practices described in the provisions against harmful tax competition. This diploma thesis was written in the course of the EUCOTAX-program 2001/2002. EUCOTAX is a scientific cooperation between several European universities (i.e. European Universities Cooperating on Taxes). The intention of this program is to provide students and young academics with the experience of participating in an international tax conference. During their time of preparation, they are supported by senior experts. In the year 2002, the general topic was Tax Competition . This topic was split up into six sub-topics which were to be discussed in groups during this year's conference. These sub-topics were State aid , OECD report on harmful tax competition , Code of conduct of business taxation , Holding companies/exempt entities , CFC legislation , and Advance rulings . The conference was held from 4 April to 12 April 2002 in Tilburg, Netherlands. Inhaltsverzeichnis:Table of Contents: Table of contents2 Dedication5 1.Preface6 2.Eu and OECD PRovisions against harmful tax competition8 2.1Are measures to curb harmful tax competition necessary?8 2.1.1Definition of harmful tax competition8 2.1.2Arguments in favor of the adoption of measures against harmful tax [...]


Introducing an Advance Tax Ruling (ATR) Regime

Introducing an Advance Tax Ruling (ATR) Regime

Author: Christophe Waerzeggers

Publisher:

Published: 2016

Total Pages: 14

ISBN-13:

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Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.


Tomorrow's Lawyers

Tomorrow's Lawyers

Author: Richard Susskind

Publisher: OUP Oxford

Published: 2013-01-10

Total Pages: 0

ISBN-13: 9780199668069

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From the bestselling author of The End of Lawyers?, this book predicts fundamental and irreversible changes in the legal world and offers essential practical advice for those who intend to build careers and businesses in law. A definitive guide to the future for aspiring lawyers, and for all who want to modernize today's legal and justice systems.


Advancing Rule of Law in a Global Context

Advancing Rule of Law in a Global Context

Author: Heru Susetyo

Publisher: CRC Press

Published: 2020-03-11

Total Pages: 290

ISBN-13: 0429829493

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The papers published in this proceedings volume are written by a selection of authors, resulting from a call for papers for the 1st International Conference on Law and Governance in a Global Context (ICLAVE) originating from Indonesia and other countries. This proceedings volume shall be a very valuable contribution to understand contemporary law issues in Indonesia which are not always taught in law schools. These proceedings will not only serve as a useful reference for law students and academicians, but also help law practitioners to understand law issues that may be encountered in Indonesia. It covers selected items such as Administrative Law, Constitutional Law, Business Law, Intellectual Property Law, Criminal Law, Human Rights Law, Adat Law, Shariah Law, Judiciary Law and International Law, which are all important for undergraduate and post-graduate law students, as well as academicians and law practitioners in the law community.


Introducing a General Anti-Avoidance Rule (GAAR)

Introducing a General Anti-Avoidance Rule (GAAR)

Author: Mr.Christophe J Waerzeggers

Publisher: International Monetary Fund

Published: 2016-01-31

Total Pages: 12

ISBN-13: 1513515829

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Tax avoidance continues to attract attention globally with strong support for tax law reform at all levels. This Tax Law IMF Technical Note focuses on some of the key design and drafting considerations of one specific legal instrument (being, a statutory general anti-avoidance rule (GAAR)) which is often considered by authorities to combat unacceptable tax avoidance practices. A GAAR is typically designed to strike down those otherwise lawful practices that are found to be carried out in a manner which undermines the intention of the tax law such as where a taxpayer has misused or abused that law. However, the objective of combating unacceptable tax avoidance can itself make the legal design of a GAAR complex. This is simply because the phrase “tax avoidance” means different things to different people. Whatever the form of a GAAR, it should give effect to a policy that seeks to strike down blatant, artificial or contrived arrangements which are tax driven. However, the GAAR should be designed and applied so as not to inhibit or impede ordinary commercial transactions. This Tax Law IMF Technical Note discusses and explores how drawing a line between those arrangements which should be caught by the GAAR is a matter of degree and can be delicate.