Cambridge Tax Law Series – serie
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33 produkter
33 produkter
1 753 kr
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The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
International Tax as International Law
An Analysis of the International Tax Regime
Häftad, Engelska, 2007
525 kr
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This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.
International Tax as International Law
An Analysis of the International Tax Regime
Inbunden, Engelska, 2007
934 kr
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This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.
1 717 kr
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This book was first published in 2006. Many common law countries inherited British income tax rules. Whether the inheritance was direct or indirect, the rationale and origins of some of the central rules seem almost lost in history. Commonly, they are simply explained as being of British origin without more, but even in Britain the origins of some of these rules are less than clear. This book traces the roots of the income tax and its precursors in Britain and in its former colonies to 1820. Harris focuses on four issues that are central to common law income taxes and which are of particular current relevance: the capital/revenue distinction, the taxation of corporations, taxation on both a source and residence basis, and the schedular approach to taxation. He uses an historical perspective to make observations about the future direction of income tax in the modern world.
645 kr
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Tax policy frequently targets the choices that women face in many aspects of their lives. Decisions regarding working away from home, having children, marrying, registering a partnership or cohabiting with a partner all entail tax consequences. The end of the twentieth century saw progress in women's legal and social equality, but many governments began to increase their reliance on the tax system as a means of influencing the choices that women make. The juxtaposition of this instrumentalist deployment of tax with persisting economic inequality for women is the starting point for this book. Employing a range of theoretical approaches, and grounding its investigations in sociological theory and cultural philosophy, it provides the foundation for a comparative, contextual consideration of the issues that arise at the intersection of women, tax policy and the law.
Anglo-American Corporate Taxation
Tracing the Common Roots of Divergent Approaches
Inbunden, Engelska, 2011
934 kr
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The UK and the USA have historically represented opposite ends of the spectrum in their approaches to taxing corporate income. Under the British approach, corporate and shareholder income taxes have been integrated under an imputation system, with tax paid at the corporate level imputed to shareholders through a full or partial credit against dividends received. Under the American approach, by contrast, corporate and shareholder income taxes have remained separate under what is called a 'classical' system in which shareholders receive little or no relief from a second layer of taxes on dividends. Steven A. Bank explores the evolution of the corporate income tax systems in each country during the nineteenth and twentieth centuries to understand the common legal, economic, political and cultural forces that produced such divergent approaches and explains why convergence may be likely in the future as each country grapples with corporate taxation in an era of globalization.
1 452 kr
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The central element of the taxpayer's relationship with the law was the protection it afforded to ensure only the correct amount of tax was paid, that it was legally levied and justly administered. These legal safeguards consisted of the fundamental constitutional provision that all taxes had to be consented to in Parliament, local tax administration, and a power to appeal to specialist tribunals and the courts. The book explains how these legal safeguards were established and how they were affected by changing social, economic and political conditions. They were found to be restrictive and inadequate, and were undermined by the increasing dominance of the executive. Though they were significantly recast, they were not destroyed. They proved flexible and robust, and the challenge they faced in Victorian England revealed that the underlying, pervasive constitutional principle of consent from which they drew their legitimacy provided an enduring protection for the taxpayer.
1 452 kr
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The United Nations in Global Tax Coordination fills the decade-long knowledge gap in international tax history concerning the UN Fiscal Commission, which functioned as the overarching fiscal authority during the early post-World War II economic order. With insights from political economy and international relations scholarship, this critical archival examination chronicles the tenacious activism by post-colonial developing countries to preserve source taxation rights, and by the UN Secretariat in championing the development of equitable tax rules. Such activism would ultimately lead developed countries to oust the UN as a forum for international tax norm setting. The book includes a revealing prehistory of the wartime work of the League of Nations that questions the legitimacy of the Mexico Model, the first model tax convention between developed and developing countries. This expertly researched work is essential reading for understanding the roles of politics, states, secretariats and private actors in directing global tax coordination.
1 211 kr
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The International Tax Revolution offers the first comprehensive analysis of the profound changes in international taxation over the past decade, culminating in the landmark October 2021 agreement by over 140 countries to implement a global corporate minimum tax and modify profit allocation and nexus rules for the digital economy. The book provides a historical narrative of how the original International Tax Regime (ITR) crumbled under the pressures of globalization and tax competition between 1980 and 2008, and how the financial crisis of 2008-2010 and subsequent cuts to social welfare programs spurred governments to adopt new approaches to taxing multinational corporations. Chapters explore the impact of globalization and tax competition on countries' ability to provide a social safety net for their citizens, and outline how the world has come together to limit such competition, modify the outdated rules, and promote greater equity in the global tax system.
1 705 kr
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New edition taking account of the substantial developments of the last decade. It considers the Trump US tax reforms of late 2017 and then the Biden reforms of 2022. It recognises the economic rise of China by incorporating its corporate tax system for comparison. This creates increased balance, introducing a second civil law jurisdiction. This edition also incorporates many changes resulting from international tax developments including the Base Erosion and Profit Shifting reports and the current Two Pillar approach. The edition documents how corporate and international tax systems are increasingly integrated. This is particularly the case with minimum taxes, hybrid financial instruments and excessive debt financing. The interface between corporate tax base and financial accounts is another area of particular interest. Countries continue to tinker with the use of corporate losses, corporate tax rates and dividend relief. Other areas of development include corporate tax subjects, buy backs and dividend stripping.
- Nyhet
1 271 kr
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Amidst calls for a return to the high tax rates of the 1950s and 60s, this book examines the tax dodging that accompanied it. Lacking political will to lower the rate, Congress riddled the laws with loopholes, exemptions, and preferences, while largely accepting income tax chiseling's rise in American culture. The rich and famous openly invested in tax shelters and de-camped to exotic tax havens, executives revamped the compensation and retirement schemes of their corporations to suit their tax needs, and an industry of tax advisers developed to help the general public engage in their own form of tax dodging through exaggerated expense accounts, luxurious business travel on the taxpayer's dime, and self-help books on 'how the insider's get rich on tax-wise' investments. Tax dodging was a part of almost every restaurant bill, feature film, and savings account. It was literally woven into the fabric of society.
1 512 kr
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A tax expenditure is a 'tax break' allowed to a taxpayer or group of taxpayers, for example, by way of concession, deduction, deferral or exemption. The tax expenditure concept, as it was first identified, was designed to demonstrate the similarity between direct government spending on the one hand and spending through the tax system on the other. The identification of benefits provided through the tax system as tax expenditures allows analysts to consider the fiscal significance of those parts of the tax system which do not contribute to the primary purpose of raising revenue. Although a seemingly simple concept, it has generated a range of complex definitional and practical issues, and this book identifies and critically assesses the controversial aspects of tax expenditure and tax expenditure management.
3 322 kr
Skickas inom 11-20 vardagar
This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions or focused on bilateral treaties in the context of the tax treaty policy of single countries, and sets the pace for a new methodology in the analysis and interpretation of tax treaties. A general report outlines the key points of the analysis, highlights current trends and predicts future developments of multilateralism and global tax law. This is an essential resource for academics, tax authorities and international tax practitioners who find textbooks based on Model Tax Conventions insufficient.
3 714 kr
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Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
The Taxation of Corporate Groups under Consolidation
An International Comparison
Inbunden, Engelska, 2012
1 512 kr
Tillfälligt slut
The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common. Antony Ting presents the first comprehensive comparative study of eight consolidation regimes in Australia, France, Italy, Japan, the Netherlands, New Zealand, Spain and the USA. In the study, he critically analyses and compares alternative policy options with respect to ten key structural elements. The study improves understanding of the design and implementation of consolidation regimes and sets the stage for the search for a model. It provides valuable information with respect to the best practices, as well as the pitfalls, in the design of a consolidation regime. The book is essential to countries contemplating the introduction of a new consolidation regime and offers important insights into the management of such a complex structure through careful policy-orientated choices.
1 380 kr
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This book integrates legal, economic, and administrative materials about the value added tax (VAT) to present the only comparative approach to the study of VAT law. The comparative presentation of this volume offers an analysis of policy issues relating to tax structure and tax base as well as insights into how cases arising out of VAT disputes have been resolved. Its principal purpose is to provide comprehensive teaching tools - laws, cases, analytical exercises, and questions drawn from the experience of countries and organizations around the world. This second edition includes new VAT-related developments in Europe, Asia, Africa, and Australia and adds new chapters on VAT avoidance and evasion and on China's VAT. Designed to illustrate, analyze, and explain the principal theoretical and operating features of value added taxes, including their adoption and implementation, this book will be an invaluable resource for tax practitioners and government officials.
1 657 kr
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This book explores one of the most significant trends in the evolution of global tax systems by asking how, within less than half a century, the value-added tax (VAT) has risen from relative obscurity to become one of the world's most dominant revenue instruments. Despite its significance, very little is known about why so many countries have adopted the VAT and, in particular, why different countries adopt the types of VAT that they do. The popular mythology provides that the merits of the VAT have underpinned its global spread; however, this book contends that much scholarship confuses the question of why the VAT has risen to dominance with the issue of what makes a good VAT. This book combines policy and legal analysis to propose a new way of understanding the rise of this important revenue instrument so as to better reflect the realities of the VATs that are actually implemented.
1 380 kr
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Bringing a unique voice to international taxation, this book argues against the conventional support of multilateral co-operation in favour of structured competition as a way to promote both justice and efficiency in international tax policy. Tsilly Dagan analyzes international taxation as a decentralized market, where governments have increasingly become strategic actors. While many of the challenges of the current international tax regime derive from this decentralized competitive structure, Dagan argues that curtailing competition through centralization is not necessarily the answer. Conversely, competition - if properly calibrated and notwithstanding its dubious reputation - is conducive, rather than detrimental, to both efficiency and global justice. International Tax Policy begins with the basic normative goals of income taxation, explaining how competition transforms them and analyzing the strategic game states play on the bilateral and multilateral level. It then considers the costs and benefits of co-operation and competition in terms of efficiency and justice.
695 kr
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This book was first published in 2006. Many common law countries inherited British income tax rules. Whether the inheritance was direct or indirect, the rationale and origins of some of the central rules seem almost lost in history. Commonly, they are simply explained as being of British origin without more, but even in Britain the origins of some of these rules are less than clear. This book traces the roots of the income tax and its precursors in Britain and in its former colonies to 1820. Harris focuses on four issues that are central to common law income taxes and which are of particular current relevance: the capital/revenue distinction, the taxation of corporations, taxation on both a source and residence basis, and the schedular approach to taxation. He uses an historical perspective to make observations about the future direction of income tax in the modern world.
404 kr
Skickas inom 7-10 vardagar
Bringing a unique voice to international taxation, this book argues against the conventional support of multilateral co-operation in favour of structured competition as a way to promote both justice and efficiency in international tax policy. Tsilly Dagan analyzes international taxation as a decentralized market, where governments have increasingly become strategic actors. While many of the challenges of the current international tax regime derive from this decentralized competitive structure, Dagan argues that curtailing competition through centralization is not necessarily the answer. Conversely, competition - if properly calibrated and notwithstanding its dubious reputation - is conducive, rather than detrimental, to both efficiency and global justice. International Tax Policy begins with the basic normative goals of income taxation, explaining how competition transforms them and analyzing the strategic game states play on the bilateral and multilateral level. It then considers the costs and benefits of co-operation and competition in terms of efficiency and justice.
697 kr
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This book integrates legal, economic, and administrative materials about the value added tax (VAT) to present the only comparative approach to the study of VAT law. The comparative presentation of this volume offers an analysis of policy issues relating to tax structure and tax base as well as insights into how cases arising out of VAT disputes have been resolved. Its principal purpose is to provide comprehensive teaching tools - laws, cases, analytical exercises, and questions drawn from the experience of countries and organizations around the world. This second edition includes new VAT-related developments in Europe, Asia, Africa, and Australia and adds new chapters on VAT avoidance and evasion and on China's VAT. Designed to illustrate, analyze, and explain the principal theoretical and operating features of value added taxes, including their adoption and implementation, this book will be an invaluable resource for tax practitioners and government officials.
1 964 kr
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Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Figuring Out the Tax
Congress, Treasury, and the Design of the Early Modern Income Tax
Inbunden, Engelska, 2018
1 477 kr
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Figuring Out the Tax recounts the forgotten early development of the federal income tax in the US, resulting from the interplay between Congress and the Treasury Department in the decades following the enactment of the tax in 1913. It covers a wide range of topics including the income tax treatments of marriage, capital losses, charitable contributions and homeownership, as well as the rise, demise and resurrection of income tax withholding. Lawrence Zelenak deftly illustrates how the income tax achieved its current form through a range of stories which are new to tax history scholarship and involve some remarkable personalities and surprising plot twists. Although of particular interest to tax academics and professionals, this book will also serve as a useful introduction to the development of income tax for undergraduate students and law students.
1 989 kr
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International Commercial Tax, 2nd edition takes account of the substantial developments of the last decade. With more than sixty percent new material, the book considers the outcomes of the OECD's BEPS project and the substantial consequential 2017 revisions of the OECD and UN Model tax treaties. With the continuing rise in the economic importance of non-OECD countries and the UK distancing itself from the EU, there has been a refocusing with less direct attention on UK domestic law and greater focus on the approaches of other significant countries, especially other common law jurisdictions. This provides greater flexibility as to how a particular point or issue is illustrated with practical examples. Greater attention is given to the UN Model, which is increasingly important. The book continues to compare the approach under model tax treaties with EU law and is updated with copious references and illustrations from the burgeoning jurisprudence of the EU Court.
1 477 kr
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The question of how to tax multinational companies that operate highly digitalised business models is one of the most contested areas of international taxation. The tax paid in the jurisdictions in which these companies operate has not kept pace with their immense growth and the OECD has proposed a new international tax compromise that will allocate taxing rights to market jurisdictions and remove the need to have a physical presence in the taxing jurisdictions in order to sustain taxability. In this work, Craig Elliffe explains the problems with the existing international tax system and its inability to respond to challenges posed by digitalised companies. In addition to looking at how the new international tax rules will work, Elliffe assesses their likely effectiveness and highlights features that are likely to endure in the next waves of international tax reform.
1 477 kr
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On subjects ranging from trade to democratization, there has lately been a wave of laments about China's development belying Western expectations. Yet these disappointments often come with misunderstandings of the very institutions that China was expected to adopt. Chinese taxation offers a sharp illustration. When China introduced a tax system suited for the market economy, it fully intended tax collection to rely on self-assessment, audits, and the rule of law. But this Western approach was quickly jettisoned in favour of one that emphasized monitoring of taxpayers and ex ante interventions, at the expense of deterrence and truthful reporting norms. The Chinese approach surprisingly matches recommendations made by recent economic scholarship on tax compliance and state capacity. China's massive but little-known explorations in taxation highlight the distinct types of modern state capacity, and raise challenging questions about the future of taxation and the superiority of institutions based on rule of law.
1 464 kr
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In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.
385 kr
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The question of how to tax multinational companies that operate highly digitalised business models is one of the most contested areas of international taxation. The tax paid in the jurisdictions in which these companies operate has not kept pace with their immense growth and the OECD has proposed a new international tax compromise that will allocate taxing rights to market jurisdictions and remove the need to have a physical presence in the taxing jurisdictions in order to sustain taxability. In this work, Craig Elliffe explains the problems with the existing international tax system and its inability to respond to challenges posed by digitalised companies. In addition to looking at how the new international tax rules will work, Elliffe assesses their likely effectiveness and highlights features that are likely to endure in the next waves of international tax reform.
368 kr
Skickas inom 7-10 vardagar
In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.
493 kr
Skickas inom 7-10 vardagar
International Commercial Tax, 2nd edition takes account of the substantial developments of the last decade. With more than sixty percent new material, the book considers the outcomes of the OECD's BEPS project and the substantial consequential 2017 revisions of the OECD and UN Model tax treaties. With the continuing rise in the economic importance of non-OECD countries and the UK distancing itself from the EU, there has been a refocusing with less direct attention on UK domestic law and greater focus on the approaches of other significant countries, especially other common law jurisdictions. This provides greater flexibility as to how a particular point or issue is illustrated with practical examples. Greater attention is given to the UN Model, which is increasingly important. The book continues to compare the approach under model tax treaties with EU law and is updated with copious references and illustrations from the burgeoning jurisprudence of the EU Court.