SCIENCE TECHNOLOGY AND TAXATION SERIES ON INTERNATIONAL TAXATION

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Science Technology And Taxation

Author : Robert F. van Brederode
ISBN : 9789041142061
Genre : Law
File Size : 74.74 MB
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This first comprehensive study of the interaction between technology and taxation approaches the subject along four main avenues: insight and analysis gained from empirical legal studies conducted in the area of taxation; methods for improving the control and management of the tax function in business; tax auditing through statistical sampling; and changes in the fiscal environment as a result of technological capabilities. Among the topics that arise are the following: what choices of sampling methodology exist; determination of both one-sided and two-sided confidence intervals; under what circumstances statistical sampling is acceptable as proof of underpayment and as a basis for penalties; the use of sampling agreements as a tool to improve taxpayers’ understanding of the process; complexities encountered by the introduction of technology in tax administration in developing countries; technological capability to detect economic activity in the informal sector; technological innovation as substitute for inadequate human capacity; improvements available to better monitor the movement and values of goods entering a country; safeguards to prevent unauthorized use of personal information; prioritizing resources to ensure that the key strategic objectives of the agency are being addressed; government defensive action and the threat to privacy; and capabilities and limitations of enterprise resource planning systems and tax engines. Although the author pays especially detailed attention to the technologies developed and used by the United States Internal Revenue Service, other notable systems developed by the European Union, Brazil, Mexico, and China are also examined. Various sampling methods and practices are illustrated with numerical examples. As tax systems acquire ever higher levels of integration, and because accuracy is crucial to the measurement of tax compliance, the perspectives opened and expertly analyzed by the author will prove of great importance. Practitioners, tax policymakers and administrators, tax standard setters, and tribunals dealing with disputes over tax administration and procedure, as well as academics and researchers, will instantly recognize the book’s great importance and practical value.
Category: Law

Borderline Case

Author : National Research Council
ISBN : 9780309063685
Genre : Political Science
File Size : 32.33 MB
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The growing integration of world markets for capital and goods, coupled with the rise of instantaneous worldwide communication, has made identification of corporations as "American," "Dutch," or "Japanese" extremely difficult. Yet tax treatment does depend of where a firm is chartered. And, as Borderline Case documents, there is little doubt that tax rules for firms doing business in several nations--firms that account for more than three-quarters of corporate R&D spending in the United States--have substantial effects on corporate decisionmaking and, ultimately, U.S. competitiveness. This book explores the impact of the U.S. tax code and its incentives on the international activities of U.S.- and foreign-based firms: basic research outlays, expenditures on product and process development, and plant and equipment investment. The authors include industry experts from large multinational firms in technology and pharmaceuticals, academic researchers who have explored the quantitative impact of tax provisions on R&D, and tax policy analysts who have examined international tax rules in the broader context of tax reform. These experts look at how corporate investment and R&D are shaped by specific tax provisions, such as the definition of taxable income, relative tax burdens on domestic and foreign business, taxation of earnings repatriated to the United States, deductibility of expenses of worldwide operations, and U.S. corporate taxes relative to other countries. The volume explores prescriptions and prospects for tax reform and reviews major reform proposals and their implications for the behavior of multinational business.
Category: Political Science

International Taxation Of Income From Services Under Double Taxation Conventions

Author : Marta Castelon
ISBN : 9789041195951
Genre : Law
File Size : 73.1 MB
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The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.
Category: Law

International Taxation Of Manufacturing And Distribution

Author : John Abrahamson
ISBN : 9789041166678
Genre : Law
File Size : 52.70 MB
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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.
Category: Law

International Taxation Of Energy Production And Distribution

Author : John Abrahamson
ISBN : 9789041191205
Genre : Law
File Size : 67.2 MB
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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.
Category: Law

International Taxation Handbook

Author : Colin Read
ISBN : 9780750683715
Genre : Business & Economics
File Size : 26.50 MB
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International taxation is evolving in response to globalization, capital mobility, and the increased trade in services, and introduces international tax practitioner, student and researcher to the theory, practice, and international examples of the changing landscape. Models of tax competition in a flat and connected world are very different than those necessary to ensure compliance in a world dominated by cross-border flows of goods and repatriation of profits. Taxes on consumption, e-commerce, and services are looming innovations in future of international taxation. Tax coordination and standardization are immense challenges in a world in which the movement of value is increasingly subtle and hard to detect. And as corporations and individuals become more sophisticated in the internationalization of flows of capital, our models must become more sophisticated in their scope and inclusion. In the era when trade was dominated by the exchange of manufactured goods, international taxation was designed to protect domestic industries, create tax revenue, prevent evasion, and promote compliance. The traditional toolbox of customs duties, tariffs, and taxes on repatriated profits must be augmented as the movement of goods across borders represents a much smaller fraction of trade and as international taxation policy is increasingly used to attract foreign corporations rather than discourage branch offices. International taxation models that can better tax services, track international flows of capital, and allow a nation to compete in a world market for capital formation are the tools of the modern tax practitioner. International tax policy is now viewed as an integral part of economic policy. This approach is bound to accelerate as the world becomes increasingly flat and better connected. Economic progress is more and more influenced by the movement of services and information, movements that are no longer through ports but through fiber optic lines. This book contributes to the growing literature on international taxation by bringing together theory and experience, current practices and innovation, and our current understanding of some of the challenges now facing and arguably frustrating current international taxation policy. The book will create new avenues of research for scholars, a new awareness for students of International Taxation, and new possibilities for international tax practitioners. The models and examples presented here suggest that there are serious problems with measurability of flows of services and information, and points to an increasingly need for greater harmonization of international taxation, perhaps through coordinated consumption-tax oriented approaches. * Describe the rapidly evolving role of International Taxation in a globalizing information economy * Present theoretical models that act as the basis for successful international tax competition * Describe the experiences and innovations of representative internationalized countries * Discuss some new approaches to International Taxation * Makes the case for new models of international taxation in an increasingly global information world
Category: Business & Economics

Catalog Of Copyright Entries Third Series

Author : Library of Congress. Copyright Office
ISBN : STANFORD:36105006357474
Genre : Copyright
File Size : 62.45 MB
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Includes Part 1, Number 1: Books and Pamphlets, Including Serials and Contributions to Periodicals (January - June)
Category: Copyright

International Company Taxation In The Era Of Information And Communication Technologies

Author : Anne Schäfer
ISBN : 3835091387
Genre : Business & Economics
File Size : 62.27 MB
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Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.
Category: Business & Economics

Chinese Tax Law And International Treaties

Author : Lorenzo Riccardi
ISBN : 9783319002750
Genre : Law
File Size : 32.11 MB
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The People’s Republic of China’s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation’s rise to the world’s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China’s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China’s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China’s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis. Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.
Category: Law

Effects Of U S Tax Policy On Greenhouse Gas Emissions

Author : National Research Council
ISBN : 9780309282697
Genre : Political Science
File Size : 50.61 MB
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The U.S. Congress charged the National Academies with conducting a review of the Internal Revenue Code to identify the types of and specific tax provisions that have the largest effects on carbon and other greenhouse gas emissions and to estimate the magnitude of those effects. To address such a broad charge, the National Academies appointed a committee composed of experts in tax policy, energy and environmental modeling, economics, environmental law, climate science, and related areas. For scientific background to produce Effects of U.S. Tax Policy on Greenhouse Gas Emissions, the committee relied on the earlier findings and studies by the National Academies, the U.S. government, and other research organizations. The committee has relied on earlier reports and studies to set the boundaries of the economic, environmental, and regulatory assumptions for the present study. The major economic and environmental assumptions are those developed by the U.S. Energy Information Administration (EIA) in its annual reports and modeling. Additionally, the committee has relied upon publicly available data provided by the U.S. Environmental Protection Agency, which inventories greenhouse gas (GHG) emissions from different sources in the United States. The tax system affects emissions primarily through changes in the prices of inputs and outputs or goods and services. Most of the tax provisions considered in this report relate directly to the production or consumption of different energy sources. However, there is a substantial set of tax expenditures called "broad-based" that favor certain categories of consumption-among them, employer-provided health care, owner-occupied housing, and purchase of new plants and equipment. Effects of U.S. Tax Policy on Greenhouse Gas Emissions examines both tax expenditures and excise taxes that could have a significant impact on GHG emissions.
Category: Political Science