This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Błażej Kuźniacki presents a route towards an international autonomous meaning of beneficial ownership, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity.
Due to the ever-changing nature of VAT, and your need to have access to the most up-to-date information, this vital VAT guide covers all recent changes. It offers a complete picture of VAT. Updates include in-depth coverage of the UK and EU legislation, HMRC material, case law, tribunal decisions and the provisions of the Finance Act 2019
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
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.
All the information a practitioner might need on indirect tax is set out in De Voil. As well as VAT, De Voil covers Customs Duties, Insurance Premium Tax, Air Passenger Duty, Landfill Tax, Climate Change Levy and Aggregates Levy. Relevant HMRC Revenue & Customs Briefs are included as well as HMRC Notices and Tribunal Guidance Notes. De Voil provides expert commentary in this complex field of taxation and is thoroughly cross-referenced to the source material. Useful case digests are also reproduced and a thorough index is included. In order to keep pace with the constant changes in the subject, De Voil is updated on a monthly basis (and incorporates the bi-weekly online service updates). The 2nd edition of Tolley's Value Added Tax annual is also included as part of your subscription.The commentary and materials are well indexed and logically arranged in divisions, ensuring that the text is readily accessible. CD-ROM is available in Bos or Folio format and includes access rights to: * Full text of HMRC Guidance Manuals on VAT and insurance premium tax (CD) * VAT Tribunal Decisions database * Orange Book legislation * Finance Act Handbook (CD)Subscribers to De Voil Indirect Tax Service will also have access to Tolley's Practice Support - a free, telephone advice service offering advisory calls. The advice line can be used to provide guidance, support or merely a second opinion on all areas of direct and indirect taxation.
This special edition of Tolley's Orange Tax Handbook brings together the key VAT legislation, fully updated to reflect the position following the end of the Brexit transition period.The Brexit-related changes to UK VAT legislation had originally been drafted on the basis of no agreement being reached on the UK's future relationship with the EU. Having struck a deal at the end of 2020 on a framework for the future, significant changes have been made to the legislation, including amendments to reflect the operation of the Ireland/Northern Ireland Protocol.This special edition of the Orange Book includes the up to date, consolidated key UK VAT legislation, along with a "snapshot" of the relevant EU VAT Directives as they stood at 11pm on 31 December 2020 (Implementation Period Completion Day). Fully updated, the special edition includes:* Value Added Tax Act 1994* Value Added Tax Regulations, SI 1995/2518* Principal EU VAT Directive (2006/112) frozen as at IP Completion Day* Selected other key UK VAT Regulations and EU legislation* Index
Qualitative Methods in Public Health: A Field Guide for Applied Research, 2nd Edition provides a practical orientation to conducting effective qualitative research in the public health sphere. With thorough examination and simple explanations, this book guides you through the logic and workflow of qualitative approaches, with step-by-step guidance on every phase of the research. Students learn how to identify and make use of theoretical frameworks to guide your study, design the study to answer specific questions, and achieve their research goals. Data collection, analysis, and interpretation are given close attention as the backbone of a successful study, and expert insight on reporting and dissemination helps you get your work noticed. This second edition features new examples from global health, including case studies specifically illustrating study design, web and mobile technologies, mixed methods, and new innovations in information dissemination. Pedagogical tools have been added to help enhance your understanding of research design and implementation, and extensive appendices show you how these concepts work in practice. Qualitative research is a powerful tool for public health, but it's very easy to get it wrong. Careful study design and data management are critical, and it's important to resist drawing conclusions that the data cannot support. This book shows you how to conduct high-quality qualitative research that stands up to review.
