Download Free Tax Arbitrage In The Netherlands Book in PDF and EPUB Free Download. You can read online Tax Arbitrage In The Netherlands and write the review.

Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice.
"This book is the product of the first Cnossen Forum-Tax by design for the Netherlands that was held on 23-24 May 2019."--Page v.
This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts. /div
"The Bible of Irish income tax ...", Irish Independent, 28 January 2018. This annual publication on Irish income tax is the long-established leading authority in the area. This tax essential, formerly known as Judge, is the leading income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It provides a complete analysis of the principles and practice of income tax in the Republic of Ireland. It also provides an examination of recent key decisions by the courts both in Ireland and in the UK, as well as by the Tax Appeal Commissioners. This new edition is updated to Finance Act 2021.
"The Bible of Irish income tax ...", Irish Independent, 28 January 2018. This tax essential, formerly known as Judge, is the leading income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It provides a complete analysis of the principles and practice of income tax in Ireland. It also provides an examination of recent key decisions by the courts both in Ireland and in the UK, as well as by the Tax Appeal Commissioners. This new edition is updated to Finance Act 2022. This title is included in Bloomsbury Professional's Irish Tax online service.
'The Bible of Irish income tax...' - Irish Independent, 28 January 2018 Tom Maguire's annual publication on Irish income tax is the long-established leading authority in the area. This immensely popular tax essential is the number one income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It endeavours to provide a complete analysis of the principles and practice of income tax in the Republic of Ireland. This new edition is based on the Finance Act 2020. It also provides an examination of recent key decisions by the courts both here and in the UK, as well as by the Tax Appeal Commissioners. The 2021 edition deals with changes in relation to pandemic unemployment payments, the dependent relative tax credit and the mobility allowance. In particular the new edition examines the impact of the Covid Restrictions Support Scheme, which is available to eligible businesses who carry on an activity that is impacted by the Covid-19 Restrictions.
A standard legal resource since its first edition in 1978, this matchless book has proven itself the ideal overview of Dutch law for foreign lawyers. This Sixth Edition fully updates its systematic description of the legal sources, institutions, and concepts in all major fields of law. Recent developments covered include the progressive implementation of standards set by international conventions, the reorganization of the judiciary, the statute on environmental law, and the (re)codification of private international law. The continuing influence of European law is evident in many fields, perhaps most notably in family law. The various chapters are written by experts – scholars and lawyers – in particular fields, and provide an authoritative overview of each field. The historical sources of Dutch law are discussed, as well as Dutch legal culture, legal philosophy, judicial organization, legal education, and the legal profession. These chapters are followed by introductions to essential issues of private and public law and labour law. The last chapter examines financial law. The only resource of its kind available, this book is unmatched as a thorough guide to further research. It offers practitioners, particularly foreign lawyers, a quick and reliable way into any area of Dutch law that they may be required to research. It will also be of great value to comparatists (especially those studying the influence of European law on national legal systems), scholars, and students. Like previous editions, the Sixth Edition has been prepared under the auspices of the Netherlands Comparative Law Association.