Integration Approaches to Group Taxation in the European Internal Market
Integration Approaches to Group Taxation in the European Internal Market

Author: Ioanna Mitroyanni

Publisher: Kluwer Law International B.V.

Published: 2008-10-13

Total Pages: 411

ISBN-13: 9041145338

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The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella. This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse. Among the topics covered. The relevant jurisprudential and legislative framework of the European Internal Market; A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers; The policies for corporate taxation in integrated markets; Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability; Tests for entitlement to group membership; Tax base integration; - Territorial delineation of the group; and Formulary apportionment. In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.

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

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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.

Tolley's Basic Science and Practice of Gas Service
Tolley's Basic Science and Practice of Gas Service

Author: Frank Saxon

Publisher: Routledge

Published: 2006-08-14

Total Pages: 534

ISBN-13: 1136355510

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This is the first of three volumes of essential reference for those concerned with the installation and servicing of domestic and industrial gas equipment. This volume explains the basic principles underlying the practical and theoretical aspects of installing and servicing gas appliances and associated equipment, from the basics of combustion, to burners, pressure and flow, transfer of heat, controls, as well as materials and processes, electrical aspects, and metering and measuring devices. The revised fourth edition is brought fully up to date with current Standards and legislation to reflect recent developments in industry, in line with requirements of the ACS Certificates of Competence and NVQs. The book includes a new section on medium to low pressure regulators for domestic properties. Covering both Natural Gas and Liquefied Petroleum Gas, the many illustrations and worked examples included throughout the text will help the reader to understand the principles under discussion. Volume 1 of the Gas Service Technology Series will enable the reader to put into practice the safe installation and servicing procedures described in the companion volumes: Domestic Gas Installation Practice (Volume 2), and Industrial and Commercial Gas Installation Practice (Volume 3). Combining a comprehensive reference with practical application in real-world engineering contexts, Volume 1 provides an essential handbook for all aspects of fundamental gas servicing technology, ideal for both students new to the field as well as professionals and none-operational professionals (e.g. Specifiers, Managers, Supervisors) as an ongoing source of reference.

International Taxation of Manufacturing and Distribution
International Taxation of Manufacturing and Distribution

Author: John Abrahamson

Publisher: Kluwer Law International B.V.

Published: 2016-02-18

Total Pages: 460

ISBN-13: 904116667X

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The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.

International Taxation of Energy Production and Distribution
International Taxation of Energy Production and Distribution

Author: John Abrahamson

Publisher: Kluwer Law International B.V.

Published: 2018-04-20

Total Pages: 407

ISBN-13: 9041191208

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Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.

Intermediation of Insurance and Financial Services in European VAT
Intermediation of Insurance and Financial Services in European VAT

Author: Claus Bohn Jespersen

Publisher: Kluwer Law International B.V.

Published: 2011-01-01

Total Pages: 450

ISBN-13: 9041137327

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The current European VAT legislation encompassing insurance and financial services, including intermediation thereof, dates back to the adoption of the Sixth VAT Directive in 1977. The definitions do not, however, encompass the current complexity of insurance and financial transactions. This has resulted in considerable confusion for fiscal authorities and for businesses when deciding upon the application of the VAT exemption. As the correct VAT treatment has a significant economic impact on businesses, a great number of cases have been referred to the Court of Justice of the European Union. This is also the reason why the European Commission presented its proposal for the future treatment of insurance and financial services, including intermediation thereof, in November 2007. The political process has not yet been finalised and if the Commission's proposal is agreed upon, the question of understanding the definitions still exists. This book deals with the exemption for intermediation of insurance and financial services within European VAT. This implies analysing the methods of interpretation applied by the Court of Justice of the European Union when interpreting the provisions regarding insurance and financial services. Furthermore, the current definitions for intermediation of insurance and financial services as provided for in the VAT Directive are analysed and conclusions are made in order to define a single concept of intermediation. These analyses are followed by various practical scenarios from case law of the Member States concerning intermediation of insurance and financial services. Finally, comments based on the analyses carried out are given on the European Commission's proposal for amending the VAT Directive and the accompanying Regulation regarding intermediation of insurance and financial services.

Tolley's Value Added Tax 2008 (Second Edition Only)
Tolley's Value Added Tax 2008 (Second Edition Only)

Author: Rhianon Davies

Publisher: Tolley

Published: 2008-09-11

Total Pages: 1849

ISBN-13: 9780754534808

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Arranged in alphabetical subject order, from Accounting Periods to Zero-Rating, this second edition brings together coverage of the UK and EC legislation, Customs material and case law and tribunal decisions on each topic. Due to the ever-changing nature of VAT, it includes the changes in the Finance Act.