Flexible Multi-tiers Dispute Resolution in International Tax Disputes
Author: Pasquale Pistone
Publisher:
Published: 2020
Total Pages:
ISBN-13: 9789087226640
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Transfer Pricing and Dispute Resolution
Author: Anuschka Bakker
Publisher: IBFD
Published: 2011
Total Pages: 807
ISBN-13: 9087221002
DOWNLOAD EBOOKThis book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
A Global Analysis of Tax Treaty Disputes
Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
Published: 2017-08-17
Total Pages: 2216
ISBN-13: 1108150381
DOWNLOAD EBOOKThis two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Integration and International Dispute Resolution in Small States
Author: Petra Butler
Publisher: Springer
Published: 2018-06-11
Total Pages: 343
ISBN-13: 3319745735
DOWNLOAD EBOOKThis book provides an insight into commercial relations between large economies and Small States, the benefits of regional integration, the role of Small States as financial centres as well as B2B and State to State dispute resolution involving Small States. Several contributions allow the reader to familiarise themselves with the general subject matter; others scrutinise the particular issues Small States face when confronted with an international dispute and discuss new and innovative solutions. These solutions range from inventive ideas to help economic growth to appropriate mechanisms of dispute resolution including inter-State dispute resolution and specific areas of arbitration such as tax arbitration. Researchers, policy advisors and practitioners will find a wealth of insights, information and practical ideas in this book.
A Guide to the Anti-Tax Avoidance Directive
Author: Werner Haslehner
Publisher: Edward Elgar Publishing
Published: 2020-06-26
Total Pages: 364
ISBN-13: 178990577X
DOWNLOAD EBOOKThis book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.
The Peaceful Settlement of International Disputes
Author: Yoshifumi Tanaka
Publisher: Cambridge University Press
Published: 2018-01-11
Total Pages: 465
ISBN-13: 1107164273
DOWNLOAD EBOOKThis book offers students a clear and systematic overview of procedures for peaceful dispute settlement in international law.
International Dispute Resolution
Author: Vesna Lazić
Publisher: Springer
Published: 2018-07-26
Total Pages: 131
ISBN-13: 946265252X
DOWNLOAD EBOOKThe contributions in this book cover a wide range of topics within modern disputeresolution, which can be summarised as follows: harmonisation, enforcement andalternative dispute resolution. In particular, it looks into the impact of harmonisedEU law on national rules of civil procedure and addresses the lack of harmonisationin the US regarding the recognition and enforcement of foreign judgments. Furthermore,the law on enforcement is examined, not only by focusing on US law, but also onhow to attach assets in order to enforce a judgment. Finally, it addresses certain typesof alternative dispute resolution. In addition, the book looks into the systems andcultures of dispute resolution in several regions of the world, such as the EU, the US andChina, that have a high impact on globalisation. Hence, the book is diverse in the senseof dealing with multiple issues in the field of modern dispute resolution./div The book offers explorations of the impact of international rules and EU law on domesticcivil procedure, through case studies from, among others, the US, China, Belgium andthe Netherlands. The relevance of EU law for the national debate and its impact on theregulation of civil procedure is also considered. Furthermore, several contributions discussthe necessity and possibility of harmonisation in the emergency arbitrator mechanisms inthe EU. The harmonisation of private international law rules within the EU, particularlythose of a procedural nature, is juxtaposed to the lack thereof in the US. Also, the bookoffers an overview of the current dispute settlement mechanisms in China. The publication is primarily meant for legal academics in private international law andcivil procedure. It will also prove useful to practitioners regularly engaged in cross-borderdispute resolution and will be of added value to advanced students, as well as to those withan interest in international litigation and more generally in the area of dispute resolution. Vesna Lazić is Senior Researcher at the T.M.C. Asser Institute, Associate Professor ofPrivate Law at Utrecht University and Professor of European Civil Procedure at theUniversity of Rijeka. Steven Stuij is an expert in Private International Law and a PhD Candidate/GuestResearcher at the Erasmus School of Law, Rotterdam. Ton Jongbloed is Guest Editor on this volume./div
Digital Revolutions in Public Finance
Author: Mr.Sanjeev Gupta
Publisher: International Monetary Fund
Published: 2017-11-01
Total Pages: 362
ISBN-13: 1484315227
DOWNLOAD EBOOKDigitization promises to reshape fiscal policy by transforming how governments collect, process, share, and act on information. More and higher-quality information can improve not only policy design for tax and spending, but also systems for their management, including tax administration and compliance, delivery of public services, administration of social programs, public financial management, and more. Countries must chart their own paths to effectively balance the potential benefits against the risks and challenges, including institutional and capacity constraints, privacy concerns, and new avenues for fraud and evasion. Support for this book and the conference on which it is based was provided by the Bill and Melinda Gates Foundation “Click Download on the top right corner for your free copy..."
International Arbitration and EU Law
Author: José R. Mata Dona
Publisher: Edward Elgar Publishing
Published: 2021-03-26
Total Pages: 643
ISBN-13: 178897400X
DOWNLOAD EBOOKThis book examines the intersection of EU law and international arbitration based on the experience of leading practitioners in both commercial and investment treaty arbitration law. It expertly illustrates the depth and breadth of EU law’s impact on party autonomy and on the margin of appreciation available to arbitral tribunals.
International Tax as International Law
Author: Reuven S. Avi-Yonah
Publisher: Cambridge University Press
Published: 2007-09-10
Total Pages: 224
ISBN-13: 9780521618014
DOWNLOAD EBOOKThis book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
