Advance Pricing Agreements

Author: Michelle Markham
Publisher: Kluwer Law International
ISBN: 9789041140425
Size: 51.20 MB
Format: PDF, Docs
View: 2337
Download Read Online
Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their 'tax risk appetite' on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) - arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time.

Tax Policy Challenges In The 21st Century

Author: Karoline Spies
Publisher: Linde Verlag GmbH
ISBN: 3709406048
Size: 80.49 MB
Format: PDF, Docs
View: 4273
Download Read Online
The Major Developments in Tax Policy Steadily increasing globalization as well as the financial and economic crisis have brought major challenges for states in ensuring budgetary consolidation while maintaining sustainable economic growth. These developments have not only influenced political and economic discussions in the 21st century, but also raise new questions on the role of taxation in the economic policy environment. National taxation systems worldwide are subject to significant changes and it is assumed that they will develop in a more co-operative way in the near future. This book aims at identifying the major developments in tax policy in the 21st century on a national as well as on an international level and gives an in-depth analysis of the challenges and risks, but also of the opportunities connected to these developments. Ist covers numerous and discrete issues ranging from challenges in the VAT/GST area, the taxation of the financial sector, the fight against aggressive tax planning, tax abuse and tax evasion, tax integration within the EU, the development of transfer pricing rules, the increasing role of co-operative compliance and good governance and the changing tax policies of developing and newly industrialized countries. The contributions in this book build upon a legal comparison of the national tax systems in the relevant fields, propose tax policy solutions where required and give ideas on how to go forward.

The Interface Of International Trade Law And Taxation

Author: Jennifer E. Farrell
Publisher: IBFD
ISBN: 9087221827
Size: 51.24 MB
Format: PDF, Docs
View: 5675
Download Read Online
This book explores the ill-defined and oft-underestimated relationship between the World Trade Organization (WTO) and taxation. By adopting a two-pronged approach, the relationship is examined in terms of the extent to which the WTO legal framework exerts influence upon domestic tax law and international tax policy, and whether it is appropriate for the WTO to play a regulatory role in the field of taxation. The book begins with an examination of the historical development of international trade law and international tax law, and demonstrates that these two separate areas of law are closely linked in terms of their underlying principles and historical evolution. The work then goes on to offer a doctrinal analysis of the tax content found in the WTO legal texts and highlights ambiguities therein.

Settling Large Tax Disputes

Author: Great Britain: National Audit Office
Publisher: The Stationery Office
ISBN: 9780102977141
Size: 31.86 MB
Format: PDF
View: 4863
Download Read Online
The National Audit Office has concluded, on the basis of an examination by former High Court tax judge Sir Andrew Park of five large tax settlements, that all five settlements were reasonable and at least one may have been better than reasonable. However, there were concerns about the processes by which the settlements were reached and over poor internal communication of the reasons for settlement which resulted in a loss of confidence in the settlements, both internally and externally. These large settlements are complex and there is no clear answer to what represents the 'right' tax liability. In each case, there was a range of justifiable positions the Department might have taken. The NAO's examination included consideration of whether the settlement in each case was as good as or better than the outcome that might be expected from litigation, taking into account the risks, cost, uncertainties and timescale of that option. It is not clear that all settlements were fully compatible with the Department's Litigation and Settlement Strategy. For instance, there are some disputes where the only possible outcomes are either that the taxpayer owes nothing or that it owes the full amount. In these circumstances, the Department's Litigation and Settlement Strategy does not permit 'splitting the difference'. The Department has acknowledged that its governance processes need strengthening and is introducing new arrangements, including the appointment of an assurance Commissioner, who will approve all large settlements

St James S Place Tax Guide 2012 2013

Author: Walter Sinclair
Publisher: Palgrave Macmillan
ISBN: 0230280021
Size: 45.53 MB
Format: PDF, Kindle
View: 3714
Download Read Online
The 41st annual edition of the leading guide to taxation in Britain. This practical and user-friendly guide is a bestseller with students, professionals, accountants and private individuals, explaining in simple terms how the UK tax system works and how best to minimise tax liabilities.

St James S Place Tax Guide 2012 2013

Author: W. Sinclair
Publisher: Springer
ISBN: 1137290803
Size: 57.20 MB
Format: PDF
View: 7310
Download Read Online
The 41st annual edition of the leading guide to taxation in Britain. This practical and user-friendly guide is a bestseller with students, professionals, accountants and private individuals, explaining in simple terms how the UK tax system works and how best to minimise tax liabilities.

International Taxation

Author:
Publisher: DIANE Publishing
ISBN: 9781568062167
Size: 19.50 MB
Format: PDF, ePub, Mobi
View: 2196
Download Read Online
Covers: whether foreign-controlled companies might have underpaid U.S. income taxes by improperly using transfer pricing; what factors, if any, affected the IRS1 ability to determine and recover any potentially underpaid taxes; and what alternatives to dealing with transfer pricing existed. Charts and tables.

Tax Guide 2000 2001

Author: W. Sinclair
Publisher: Springer
ISBN: 0230595790
Size: 69.84 MB
Format: PDF, Kindle
View: 6536
Download Read Online
This is the 29th edition of the leading guide to taxation in Britain. It is fully updated following the Finance Act 2000 and contains full coverage of taxes and the main implications of taxes. A bestseller with professionals and private individuals it is a practical guide which explains in simple terms how the tax system works and how to best minimise tax liabilities.