Beneficial Ownership in Tax Law and Tax Treaties, Gonzбlez-Barreda Pablo A. Hernбndez
Автор: Pablo A Hernandez Gonzalez-Barreda Название: Beneficial Ownership in Tax Law and Tax Treaties ISBN: 1509923071 ISBN-13(EAN): 9781509923076 Издательство: Bloomsbury Academic Рейтинг: Цена: 15840.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: This book explores the concept of beneficial ownership in equity law, and in the domestic tax laws of the United Kingdom, Canada and the United States; as well as its varied and increasing uses in international tax law. By analysing the evolution of beneficiary rights in equity and the use of beneficial ownership wording in tax law, the book draws a roadmap for dealing with beneficial ownership in tax law and international tax law. This approach highlights those common misconceptions that can be avoided by understanding the origins of the concept and its engagement with equity, as well as the differences with tax law. However, the book does not limit itself to dealing with theoretical discussion, but also offers an instructive and detailed practical case study. Offering both academic commentary and a practitioner focus, the book will be of the utmost interest to practitioners and scholars from common and civil law countries dealing with tax and estate law, particularly given beneficial ownership’s increasing relevance.
Автор: Lang, Michael Aigner, Hans-joergen Scheuerle, Ulrich Stefaner, Markus Название: Cfc legislation, tax treaties and ec law ISBN: 9041122842 ISBN-13(EAN): 9789041122841 Издательство: Неизвестно Рейтинг: Цена: 49658.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: This Special Issue presents proceedings of the International Conference on Behavioral Health and Traumatic Brain Injury convened in October 2008 that brought together over 100 international scientists, health care professionals, policy makers, US Military personnel, and family members, addressing the issues of mild traumatic brain injury and post traumatic stress disorder in the military.
The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects.
This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include:
- the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties;
- the scope of the MLI in order to ascertain which tax treaties and taxes are covered;
- the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties;
- the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI;
- the legal consequences of the exercise of options and reservations for the other states;
- the notification procedure through which states declare their choices; and
- the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI.
Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention.
The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
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