Carlo Garbarino – författare

Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.Key Features:Exploration of the scope of the GloBE RulesAccessible explanations of technical jargon accompanied by examplesFocus on key concepts of GloBE Income or Loss and Adjusted Covered TaxesConcise descriptions of each area of OECD policies on the global minimum taxInvestigation into the mechanism currently being used to apply the global minimum taxExamination of domestic qualified minimum taxes that align with OECD standardsAnalysis of tax neutrality and distribution regimesThis thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.

Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.

Key Features:

Exploration of the scope of the GloBE RulesAccessible explanations of technical jargon accompanied by examplesFocus on key concepts of GloBE Income or Loss and Adjusted Covered TaxesConcise descriptions of each area of OECD policies on the global minimum taxInvestigation into the mechanism currently being used to apply the global minimum taxExamination of domestic qualified minimum taxes that align with OECD standardsAnalysis of tax neutrality and distribution regimes

This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.

Judicial Interpretation of Tax Treaties is a detailed, comprehensive analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to the OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: Firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation. Key features:- A detailed and structured introduction to the main issues of tax treaties- Ideal for practitioners requiring a grounding in the functioning of tax treaty law- Concise summaries of the relevant issues, cases, and problems for each discrete chapter- Offers a basic 'globalized' handbook that is missing in the current literature about judicial application of tax treaties.This comprehensive treatment of tax treaty law is a ready reference for tax practitioners, and an essential introduction for non-specialists. The book can also be used as a companion to courses in international taxation.

Judicial Interpretation of Tax Treaties is a detailed, comprehensive analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to the OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value.

The book operates on two levels: Firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.

Key features:

- A detailed and structured introduction to the main issues of tax treaties- Ideal for practitioners requiring a grounding in the functioning of tax treaty law- Concise summaries of the relevant issues, cases, and problems for each discrete chapter- Offers a basic ''globalized'' handbook that is missing in the current literature about judicial application of tax treaties.

This comprehensive treatment of tax treaty law is a ready reference for tax practitioners, and an essential introduction for non-specialists. The book can also be used as a companion to courses in international taxation.

The OECD's guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties. Key features include:Practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment Chapters that explore specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and CommentaryExplanation of how BEPS treaty rules affect a range of corporate tax strategies including: permanent establishment, use of corporate vehicles and intra-group transactionsInformation on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement.Providing a succinct and practical approach to the topic, this book will be an insightful resource for those practising in the field of international taxation as well as corporate in-house counsel. Researchers and students seeking clear information on BEPS and its real world application affecting tax treaties will also benefit from this concise guide.