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The recent introduction of the Directive on Administrative Cooperation in the field of taxation 6 (DAC6) and mandatory disclosure regimes by many jurisdictions have led to a large number of professionals potentially being required to disclose information in relation to their clients’ arrangements. The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years including the OECD common reporting standards DAC6 and MDR. They set them in their historical context as well as giving a technical analysis of the regimes. They focus on the guidance offered by the Irish and UK tax authorities with reference to other guidance in Europe and beyond, where appropriate.
The recent introduction of the Directive on Administrative Cooperation in the field of taxation 6 (DAC6) and mandatory disclosure regimes by many jurisdictions have led to a large number of professionals potentially being required to disclose information in relation to their clients' arrangements. The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years including the OECD common reporting standards DAC6 and MDR. They set them in their historical context as well as giving a technical analysis of the regimes. They focus on the guidance offered by the Irish and UK tax authorities with reference to other guidance in Europe and beyond, where appropriate.
Insurance Premium Tax is a guide for practitioners and those involved in the insurance industry. It summarises how the IPT is applied in practice, the definition of an insurance contract, looks at exemptions from the tax, the application of the higher rate and issues affecting non UK risks and global policies. It also explores compliance issues such as IPT registration, the submission of returns and payment of the tax, changes in rates and the penalty regime.
Each chapter of this book describes and discusses a single principle which can be discerned in the design and operation of the Gibraltar taxation system. Not all of these principles will have been in the minds of the drafters of the relevant legislation, some of them may well be what philosophers call ‘emergent’ properties, but nonetheless are there, shaping and guiding the design of new legislation and impacting on the future of our taxation model.
Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
Starting with an overview of the development of money laundering and the work of international organisations, International Guide to Money Laundering Law and Practice is a unique publication providing a detailed insight into the background of money laundering operations, clearly explaining the anti-money laundering laws and regulations in 35 key global financial centres throughout the world. In addition, there are four chapters considering money laundering law and practice in the UK with the emphasis on the legal and regulatory framework and include: a chapter on the accounting and auditing issues; and a chapter on confiscating the proceeds of crime written by Jonathan Fisher, QC, a leading barrister specialising in corporate and financial crime, proceeds of crime and tax cases. It also contains a chapter covering international responses and initiatives to money laundering. The fifth edition covers, amongst other things, the implementation of the Fifth EU Money Laundering Directive and the Criminal Finances Bill. Written by local experts and edited by a team from Baker McKenzie's Financial Services Group, International Guide to Money Laundering Law and Practice is the leading, authoritative text on this heavily regulated area of law. It is essential for all banking and finance practitioners involved in anti-money laundering, banks, compliance officers and regulators in order to keep abreast of the developments and compliant with the law and regulations internationally.
There's never been a greater likelihood a company and its key people will become embroiled in a cross-border investigation. But emerging unscarred is a challenge. Local laws and procedures on corporate offences differ extensively - and can be contradictory. To extricate oneself with minimal cost requires a nuanced ability to blend understanding of the local law with the wider dimension and, in particular, to understand where the different countries showing an interest will differ in approach, expectations or conclusions. Against this backdrop, GIR has published the second edition of The Practitioner's Guide to Global Investigation. The book is divided into two parts with chapters written exclusively by leading names in the field. Using US and UK practice and procedure, Part I tracks the development of a serious allegation (whether originating inside or outside a company) - looking at the key risks that arise and the challenges it poses, along with the opportunities for its resolution. It offers expert insight into fact-gathering (including document preservation and collection, witness interviews); structuring the investigation (the complexities of cross-border privilege issues); and strategising effectively to resolve cross-border probes and manage corporate reputation.Part II features detailed comparable surveys of the relevant law and practice in jurisdictions that build on many of the vital issues pinpointed in Part I.
International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Luxembourg in International Tax' takes an in-depth look at corporate taxation in Luxembourg and the tax issues that may be of interest in an international environment. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear explanation of corporate tax in Luxembourg, it is also of interest to locally based practitioners. The first edition rapidly became a standard reference work in Luxembourg tax literature, and its reputation was maintained through the second edition, which continued being referred to and selling long after the date of issue. 0This new edition of the book is updated to incorporate tax developments on the national level up to January 2015, including the latest changes on the exchange of information, advance tax clearances and the codification of the arm’s length standard. It also covers Luxembourg’s intellectual property box regime, private wealth management companies and other investment entities, and the taxation of financing activities in Luxembourg. Furthermore, it contains a new chapter on tax treaties, which provides insight into the particularities of Luxembourg’s treaty network and its interaction with domestic law. 0The book provides a vast amount of up-to-date information combined with an in-depth analysis of business taxation in Luxembourg. It is a valuable guide for international tax experts wishing to gain a better understanding of corporate tax in Luxembourg as well as for locally based practitioners. With numerous examples given in each chapter, it will also be of interest to students.
A vital text for practitioners and academics this book integrates the international law of political risk with the domestic, political, and economic considerations central to assessing risk. It offers a detailed analysis of pre-investment decisions that can reduce political risk, treaties protecting investment, and international dispute resolution.