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Selectivity In State Aid Law And The Methods For The Allocation Of The Corporate Tax Base

Author: Jerome Monsenego
Publisher: Kluwer Law International
ISBN: 9789041194138
Size: 62.86 MB
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Selectivity in State Aid Law and the Methods for the Allocation of the Corporate Tax Base Jérôme Monsenego High profile cases before the European Commission and the EU courts have intensified scrutiny of the link between State aid law and the taxation of multinational enterprises. Certain decisions have raised questions about fiscal sovereignty and the interpretation of the rules on State aid - in particular the notion of selectivity, which have not been addressed in detail by existing research. The combination of the evolution of the notion of selectivity in State aid law, on the one hand, and the need to adapt the rules for the taxation of the profits of multinational enterprises to the modern economy, on the other hand, makes it necessary to assess whether existing as well as alternative rules for the allocation of the corporate tax base might entail a selective treatment. This book responds to the need of research in the area of State aid law applied to the taxation of the income of multinational enterprises, focusing on the crucial concept of selectivity. The analysis proceeds with a detailed investigation of the theoretical issues that arise when applying the selectivity test in State aid law to three methods for the allocation of the corporate tax base between the members of multinational enterprises: the arm's length principle; transfer pricing safe and systems of formula apportionment. This research project is conducted at a theoretical level, without considering national provisions or particular tax treaties. The author suggests an analytical framework on the application of the selectivity test to the three allocation methods. It is concluded that these methods are likely to have certain selective features, with varying possibilities to be justified by the inner logic of a corporate income tax system. It is also demonstrated that selectivity occurs for different reasons, due to the different rationales of the three allocation methods. This book is intended at contributing to the academic literature on the impact of State aid law on the principles for the taxation of the income of multinational enterprises. The outcome of this research project is also relevant for lawmakers who need to reconcile the imperatives of State aid law with the design of rules that match their tax policies, as well as for judges or lawyers who apply the rules on State aid to tax provisions.

Fiscal Sovereignty Of The Member States In An Internal Market

Author: Jacobus Johannes Maria Jansen
Publisher: Kluwer Law International B.V.
ISBN: 9041134034
Size: 26.21 MB
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The book deals with national sovereignty of Member States in tax matters, and the tensions created by the fact that the decisions by the European Court of Justice requires them to exercise consistently with the Community law. Contributions in the book cover a variety of critical issues, including the current and possible future effects of the internal market on the fiscal sovereignty of Member States; the limits that European law imposes on Member States' policy sovereignty in matters of international tax law; the effect of European law on taxes levied by local authorities; and the consequences the Treaty of Lisbon may have for Member States' fiscal sovereignty.

Transfer Pricing In The Us

Author: Felix I. Lessambo
Publisher:
ISBN: 9789041191960
Size: 65.36 MB
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This concise, practical guide to the latest issues in the rapidly evolving legal regime on transfer pricing in the US context fills the need to gain a firm grasp of transfer pricing rules and practice for corporate counsel and practitioners worldwide, enabling them to prepare compliant solutions and strategies and avoid pitfalls. The book begins with a general introduction to transfer pricing and then discusses the current OECD's Transfer Pricing Guidelines, which form the basis for most transfer pricing rules around the world. The book describes in detail the approved methods for tangible and intangible property, cost sharing, services and the best method rule. Then the book discusses functional analysis for the various methods, including the necessary documentation and penalty rules. This book is an indispensable resource for practitioners and academics, and it will be very useful to state tax authorities.

Counseling The Nursing Mother

Author: Judith Lauwers
Publisher: Jones & Bartlett Publishers
ISBN: 1284052648
Size: 51.92 MB
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Written from a teaching perspective, Counseling the Nursing Mother: A Lactation Consultant’s Guide, Sixth Edition presents topics within a counseling framework with practical suggestions and evidence-based information interwoven throughout. Completely updated and revised, it includes new research on milk composition, the importance of the gut microbiome and skin-to-skin care, Affordable Care Act changes, and the latest guidelines from the World Health Organization for breastfeeding with HIV. Also explored and expanded are discussions on cultural competence, working effectively and sensitively with LGBTQ families, addressing disparities in health equity, milk banking issues, and social media trends for lactation information and support. Additionally, the Sixth Edition also serves as a significant teaching tool for students, interns, and other healthcare professionals.Important Notice:The digital edition of this book is missing some of the images or content found in the physical edition

Tax Treaty Interpretation

Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9041198571
Size: 12.72 MB
Format: PDF, Kindle
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Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.

Limitation On Benefits Clauses In Double Taxation Conventions

Author: Félix Alberto Vega Borrego
Publisher: Eucotax Series on European Tax
ISBN: 9789041161352
Size: 61.77 MB
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This second edition analyses the legal framework and application of limitation on benefits clauses (LOB) in double taxation conventions (DTC), including detailed coverage of major recent developments such as the recent tax treaties concluded between the US and EU member states, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting, and relevant new rulings handed down by the European Court of Justice.

Ecj Recent Developments In Direct Taxation

Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9041125094
Size: 64.86 MB
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A growing number of cases pending before trhe European Court of Justice (ECJ) concern the fundamental freedoms and direct taxation. This book scrutinises the national background of the most important of these cases and examines possible infringements of fundamental freedoms. The focus of each analysis is on the questions submitted to the ECJ by the national courts. Moreover, where available, the opinion of the Advocate General is discussed. The cases are presented by esteemed national and European tax law experts. This book goes to the heart of the national tax systems, exposing hidden obstacles to fundamental freedoms.

The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes

Author: Bruno Da Silva
Publisher:
ISBN: 9789041169051
Size: 65.38 MB
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Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities - differences arising from the interaction of different tax systems - and obstacles - distortions created by domestic legislation arising from differences between domestic and cross-border situations - both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: analysis of the different tax group regimes adopted by different countries; advantages and disadvantages of a variety of models; application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; interrelations between tax treaties and EU Law in the context of tax groups; and per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.

From Marks Spencer To X Holding

Author: Dennis Manolito Weber
Publisher: Kluwer Law International B.V.
ISBN: 9041133992
Size: 75.34 MB
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The book deals with European law aspects of two European Court of Justice cases concerning cross-border tax relief claims and the decisions which have been criticized for lack of clarity and for breach of the freedom of establishment (Article 49 TFEU). The papers collected in the book cover the following issues: the underlying tax obstacles which exist for companies operating in more than one Member State; potential for tax avoidance; prevention of double use of losses (the 'no possibilities' test); disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty; the concept of 'balanced allocation of taxing powers'; meaning of 'final losses'; the 'Bosal fix'; cash-flow disadvantages of having to carry losses forward; deduction of currency losses; deduction-and-recapture rules; and VAT grouping.

Europe China Tax Treaties

Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9041132163
Size: 44.93 MB
Format: PDF
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This network aims at initiating and coordinating both comparative education in taxation, through the organisation of activities such as winter courses and guest lectures, and comparative research in the field, by means of joint research projects, international conferences and exchange of researchers between various countries. --