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Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.
This book provides a comprehensive in-depth analysis of the similarities and differences between consumption taxes and direct taxes. Fifty contributions are included, written by academics, practitioners and representatives from several international tax administrations and institutions.
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
No government can be sustained without the ability to tax its citizens. The question then arises how can a nation do so in a way that's fair and equitable to taxpayers while simultaneously promoting economic growth and providing the state with the funds it needs to adequately address the needs of its citizens? This insightful work, featuring contributions from a stellar array of international tax experts and economists, addresses the crucial, relevant issues which developed countries will confront in the early decades of the 21st century: The pursuit of tax reform. Personal tax base: income or consumption? Tax rate scale: equity and efficiency aspects. Business tax reform: structural and design issues. Interjurisdictional issues. Controlling tax avoidance.
Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.
The second edition of this highly recommended work addresses the interaction between conflict of laws, dispute resolution, electronic commerce and consumer contracts. In addition it identifies specific difficulties that conflicts lawyers and consumer lawyers encounter in electronic commerce and proposes original approaches to balance the conflict of interest between consumers' access to justice and business efficiency. The European Union has played a leading role in this area of law and its initiatives are fully explored. It pays particular attention to the most recent development in collective redress and alternative/online dispute resolution. By adopting multiple research methods, including a comparative study of the EU and US approach; historical analysis of protective conflict of laws; doctrinal analysis of legal provisions and economic analysis of law, it provides the most comprehensive examination of frameworks in cross-border consumer contracts.
Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.
This book presents an analysis of the challenges the spread of the digital economy poses for international taxation.