Ship financing and taxation
Ship financing and taxation

Author: United States. Congress. House. Committee on Merchant Marine and Fisheries. Subcommittee on Merchant Marine

Publisher:

Published: 1986

Total Pages: 516

ISBN-13:

DOWNLOAD EBOOK

International Taxation of Banking
International Taxation of Banking

Author: John Abrahamson

Publisher: Kluwer Law International B.V.

Published: 2020-02-20

Total Pages: 468

ISBN-13: 9403510951

DOWNLOAD EBOOK

Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Hybrid Financial Instruments, Double Non-Taxation and Linking Rules
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules

Author: Félix Daniel Martínez Laguna

Publisher: Kluwer Law International B.V.

Published: 2019-06-12

Total Pages: 668

ISBN-13: 9403510846

DOWNLOAD EBOOK

Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

Model Tax Convention on Income and on Capital 2017 (Full Version)
Model Tax Convention on Income and on Capital 2017 (Full Version)

Author: OECD

Publisher: OECD Publishing

Published: 2019-04-25

Total Pages: 2624

ISBN-13: 9264306994

DOWNLOAD EBOOK

This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...

Ships and Silver, Taxes and Tribute
Ships and Silver, Taxes and Tribute

Author: Hans van Wees

Publisher: Bloomsbury Publishing

Published: 2013-09-04

Total Pages: 224

ISBN-13: 0857722905

DOWNLOAD EBOOK

Historians since Herodotus and Thucydides have claimed that the year 483 BCE marked a turning point in the history of Athens. For it was then that Themistocles mobilized the revenues from the city's highly productive silver mines to build an enormous war fleet. This income stream is thought to have become the basis of Athenian imperial power, the driving force behind its democracy and the centre of its system of public finance. But in his groundbreaking new book, Hans van Wees argues otherwise. He shows that Themistocles did not transform Athens, but merely expanded a navy-centred system of public finance that had already existed at least a generation before the general's own time, and had important precursors at least a century earlier. The author reconstructs the scattered evidence for all aspects of public finance, in archaic Greece at large and early Athens in particular, to reveal that a complex machinery of public funding and spending was in place as early as the reforms of Solon in 594 BCE. Public finance was in fact a key factor in the rise of the early Athenian state - long before Themistocles, the empire and democracy.

The International Handbook of Shipping Finance
The International Handbook of Shipping Finance

Author: Manolis G. Kavussanos

Publisher: Springer

Published: 2016-11-10

Total Pages: 459

ISBN-13: 1137465468

DOWNLOAD EBOOK

The International Handbook of Shipping Finance is a one-stop resource, offering comprehensive reference to theory and practice in the area of shipping finance. In the multibillion dollar international shipping industry, it is important to understand the various issues involved in the finance of the sector. This involves the identification and evaluation of the alternative sources of capital available for financing the ships, including the appraisal and budgeting of shipping investment projects; legal and insurance aspects of ship finance; the financial analysis and modelling of investment projects; mergers and acquisitions; and the commercial and market risk management issues involved. Edited by two leading academics in this area, and with contributions from 25 prominent market practitioners and academics over 16 chapters, this Handbook covers shipping finance and banking, maritime financial management and investments. As such, it includes: shipping markets; asset backed finance; shipbuilding finance; debt finance; public and private equity and debt markets; structured finance; legal aspects and key clauses of ship mortgages; marine insurance; mechanisms for handling defaulted loans; investment appraisal and capital budgeting; financial analysis and investment modelling; business risk management and freight derivatives; and mergers and acquisitions. Thus, the Handbook offers a rigorous understanding of the different aspects of modern shipping finance and maritime financial management and investments, the various characteristics of the available products, the capital needs and requirements, and a clear view on the different financial management strategies through a series of practical examples and applications. Technical where appropriate, but grounded in market reality, this is a “must-have” reference for anyone involved in shipping finance, from bank practitioners and commodity trading houses, to shipbrokers, lawyers and insurance houses as well as to university students studying shipping finance. Table of Contents Preface by Editors Manolis Kavussanos, Professor, Director, MSc in International Shipping, Finance and Management, Athens University of Economics and Business, Greece Ilias Visvikis, Professor, Director Executive Education and Professional Development, World Maritime University, Sweden Chapter 1: Shipping Markets and their Economic Drivers Jan-Henrik Huebner, Head of Shipping Advisory, DNV GL, Germany Chapter 2: Asset Risk Assessment, Analysis and Forecasting in Asset Backed Finance Henriette Brent Petersen, Head of Shipping & Offshore Research, DVB Bank SE, The Netherlands Chapter 3: Overview of Ship Finance Fotis Giannakoulis, Research Vice President, Morgan Stanley, USA Chapter 4: Shipbuilding Finance Charles Cushing, C.R. Cushing & Co. Inc., USA Chapter 5: Debt Financing in Shipping George Paleokrassas, Partner, Watson, Farley & Williams, Greece Chapter 6: Public Debt Markets for Shipping Basil Karatzas, Founder & CEO, Karatzas Marine Advisors & Co., USA Chapter 7: Public and Private Equity Markets Jeffrey Pribor, Global Head, Maritime Investment Banking, Jefferies LLC, USA Cecilie Lind, Associate Investment Banking, Jefferies LLC, USA Chapter 8: Structured Finance in Shipping Contributor: Ioannis Alexopoulos, Director, Shipping Financier, Eurofin Group, Greece Nikos Stratis, Managing Director of Augustea Group, UK Chapter 9: Key Clauses of a Shipping Loan Agreement Kyriakos Spoullos, Solicitor, Norton Rose Fulbright, Greece Chapter 10: Legal Aspects of Ship Mortgages Simon Norton, Lecturer, Cardiff Business School, UK Claudio Chistè, Investec Bank Plc., UK Chapter 11: Reasons and Mechanics of Handling Defaulted Shipping Loans and Methods of Recovery Dimitris Anagnostopoulos, Board Member & Director, Aegean Baltic Bank, Greece Philippos Tsamanis, VP - Head of Shipping, Aegean Baltic Bank, Greece Chapter 12: Marine Insurance Marc Huybrechts, Professor, University of Antwerp, Belgium Theodora Nikaki, Associate Professor, Swansea University, UK Chapter 13: Maritime Investment Appraisal and Budgeting Wolfgang Drobetz, Professor, University of Hamburg, Germany Stefan Albertijn, CEO, HAMANT Beratungs-und Investitions GmbH, Germany Max Johns, Managing Director, German Shipowners’ Association, Germany Chapter 14: Financial Analysis and Modelling of Ship Investments Lars Patterson, Shipping Investment Analyst, Pacomarine Limited, UK Chapter 15: Maritime Business Risk Management Manolis Kavussanos, Professor, Director, MSc in International Shipping, Finance and Management, Athens University of Economics and Business, Greece Ilias Visvikis, Professor, Director Executive Education and Professional Development, World Maritime University, Sweden Chapter 16: Mergers and Acquisitions in Shipping George Alexandridis, Associate Professor, ICMA Centre, University of Reading, UK Manish Singh, Manish Singh, Group Director - Strategy and M&A, V. Group Limited, UK