Permanent CFC Look-Through Act of 2014
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Published: 2014
Total Pages: 16
ISBN-13:
DOWNLOAD EBOOKRead and Download eBook Full
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Published: 2014
Total Pages: 16
ISBN-13:
DOWNLOAD EBOOKAuthor: United States. Congress. House. Committee on Ways and Means
Publisher:
Published: 2014
Total Pages:
ISBN-13:
DOWNLOAD EBOOKAuthor: United States. Congress. House
Publisher:
Published: 2014*
Total Pages:
ISBN-13:
DOWNLOAD EBOOKAuthor:
Publisher:
Published: 2014
Total Pages: 0
ISBN-13:
DOWNLOAD EBOOKAuthor: United States. Congress. House. Committee on Ways and Means
Publisher:
Published: 2015
Total Pages: 184
ISBN-13:
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Publisher:
Published: 2016
Total Pages: 264
ISBN-13:
DOWNLOAD EBOOKAuthor: Nathalie Bravo
Publisher: Linde Verlag GmbH
Published: 2021-09-21
Total Pages: 536
ISBN-13: 3709411580
DOWNLOAD EBOOKAn in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author:
Publisher:
Published: 2013
Total Pages: 574
ISBN-13:
DOWNLOAD EBOOKAuthor: OECD
Publisher: OECD Publishing
Published: 2015-10-05
Total Pages: 75
ISBN-13: 9264241159
DOWNLOAD EBOOKAddressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Author: Ajit Kumar Singh
Publisher: Kluwer Law International B.V.
Published: 2021-05-14
Total Pages: 234
ISBN-13: 9403533641
DOWNLOAD EBOOKIn an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.