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Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
This book is a broad and detailed examination of the native title jurisprudence in the US, Canada, New Zealand and Australia, with a specific focus on the handling of Indigenous community changes in each country's case law.
In a time where governments and civil society organizations are putting ever-greater stock in social innovation as a route to transformation, understanding what characterizes social innovation with transformative potential is important. Exciting and promising ideas seem to die out as often as they take flight, and market mechanisms, which go a long way towards contributing to successful technical innovations, play an insignificant role in social innovations. The cases in this book explore the evolution of successful social innovation through time, from the ideas which catalysed social and system entrepreneurs to create new processes, platforms, projects and programs to fundamental social shifts in culture, economics, laws and policies which occurred as a result. In doing so, the authors shed light on how to recognize transformative potential in the early stage innovations we see today.
Twenty-seven chapters represent an historical approach to the discipline of psychology and together outline the development of the field. The book describes the founding of the discipline, its development as a natural science and then as a social and behavioral science, and contemporary practices. Psychological practices are situated in the larger social, cultural, and political history, and related to unemployment, gender relations, anti-Semitism, and civil rights. The methods of historical inquiry are also discussed. c. Book News Inc.
In Sanctions Regimes of Multilateral Development Banks: What Process is Due, Jelena Madir examines the type of due process rights and the level of transparency that should characterise sanctions regimes of multilateral development banks.
Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.
’Inquisitorial processes’ refers to the inquiry powers of administrative governance and this book examines the use of these powers in administrative law across seven jurisdictions. The book brings together recent developments in mixed inquisitorial-adversarial administrative decision-making on a hitherto neglected area of comparative administrative process and institutional design. Reaching important conclusions about their own jurisdictions and raising questions which may be explored in others, the book's chapters are comparative. They explore the terminology and scope of the concept of inquisitorial process, justifications for the use of inquiry powers, the effectiveness of inquisitorial processes and the implications of the adoption of such powers. The book will set in motion continued dialogue about the inherent challenges of balancing policy goals, fairness, resources and institutional design within administrative law decision-making by offering theoretical, practical and empirical analyses. This will be a valuable book to government policy-makers, administrative law decision-makers, lawyers and academics.
The Cambridge Handbook of Sexual Development is a carefully curated conversation that brings together the top researchers in child and adolescent sexual development to redefine the issues, conflicts, and debates in the field. The Handbook is organized around three foundational questions: first, what is sexual development? Second, how do we study sexual development? And third, what roles might adults - including the institutions of the media, family, and education - play in the sexual development of children and adolescents? As the first of its kind, this collection integrates work from sociology, psychology, anthropology, history, education, cultural studies, and allied fields. Writing from different disciplinary traditions and about a range of international contexts, the contributors explore the role of sexuality in children's and adolescents' everyday experiences of identity, family, school, neighborhood, religion, and popular media.
In this collection authors apply spatial analysis to case studies of social, economic, and political dynamics in West, Central, and East Africa during the nineteenth and twentieth century. Also included is a lengthy essay re-interpreting tropical Africa, 1800-1930, using spatial theory.