Language : English
Published : 2018-03-01
Pages : 700
Schwarz on Tax Treaties
Schwarz on Tax Treaties is the definitive analysis of tax treaties from a UK perspective and provides in depth expert analysis of the interpretation and interaction of the UK’s treaty network with EU and international law in their application to UK tax law. Schwarz on Tax Treaties has established itself as a standard reference work on this challenging subject. The fifth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, international and EU treaty developments including: New Bilateral double tax and exchange of information treaties and protocols OECD BEPS Multilateral Instrument Treaty binding compulsory arbitration State Aid — Luxembourg Alleged aid to McDonald’s Judicial decisions of United Kingdom and foreign courts on UK treaties Taxpayer rights in EU exchange of information Multilateral MOU on Country-By-Country Reporting EU Anti-Tax Avoidance Directive Case law developments including: UK Supreme Court in Miller, R (oao) v Secretary of State for Exiting the EU Australian High Court in Bywater Investments Ltd and others v CoT Indian Supreme Court in Formula One World Championship Ltd v CIT UK Tax Tribunals Irish Bank Resolution Corporation Ltd v HMRC; Fowler v HMRC; R (oa Derrin Brother Properties Ltd), Vrang v HMRC, Ardmore Construction CJEU in Austria v Germany; Berlioz Investment Fund SA v Directeur de l’administration des Contributions directes; Eqiom SAS and Enka SA v. Ministre des finances et des comptes Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and advice on solving cross-border tax problems. He is a visiting Professor at King’s College London and a member of the Permanent Scientific Committee of the International Fiscal Association. He has been listed as a leading tax Barrister in both the Legal 500 for international corporate tax, and Chambers’ Guide to the Legal Profession for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’.
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In Guide to International Transfer Pricing, global practitioners address both the general issues that surround transfer pricing, including the Organisation for Economic Co-operation of Development’s (OECD) fifteen-item Base Erosion and Profit Shifting (BEPS) plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance. Not only must a multinational company understand the different nuances in the transfer pricing laws and their practical interpretation in each local country, but it must also appreciate that by operating in jurisdictions with varying tax rates, transactional structures or intercompany pricing policies can impact the multinational’s global effective tax rate.
What’s in this book:
This guide is a collaboration of many transfer pricing experts from around the world with experience gained from assisting multinationals in implementing planning and compliance strategies, and their insights into dealing with local tax authorities. Key features of this book include:
- overview of fundamental concepts applied in transfer pricing;
- country-specific profiles that compare and contrast rules and real-world applications over multiple jurisdictions, including those likely to adopt BEPS; and
- practical guidance and implementation, enabling the reader to execute a coordinated, cost-effective approach to global policies and documentation needs.
How this will help you:
This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters, covering domestic transfer pricing issues in a variety of key national jurisdictions. The primary objective of this book is to arm the constituents impacted by transfer pricing, including tax directors, legal counsel, accounting and operations personnel, CFOs and outside advisors, with the knowledge base and resources needed for effective transfer pricing decision-making.
About the Author
Dr. Jeff Madura presently serves as the SunTrust Bank Professor of Finance at Florida Atlantic University. He has written several successful finance texts, including INTERNATIONAL FINANCIAL MANAGEMENT. His research on international finance has been published in numerous journals, including JOURNAL OF FINANCIAL AND QUANTITATIVE ANALYSIS; JOURNAL OF MONEY, CREDIT AND BANKING; FINANCIAL MANAGEMENT; JOURNAL OF FINANCIAL RESEARCH; and FINANCIAL REVIEW. Dr. Madura has received multiple awards for excellence in teaching and research, and has served as a consultant for international banks, securities firms, and other multi-national corporations. He earned his B.S. and M.A. from Northern Illinois University and his D.B.A. from Florida State University. Dr. Madura has served as a director for the Southern Finance Association and Eastern Finance Association and is also former president of the Southern Finance Association.
The Singapore Tax Workbook 2015/16, 18th Edition is the recommended taxation textbook for tax professionals, university and polytechnic courses. It is the most up-to-date, user-friendly and practical workbook for tax and accounting students.
The Singapore Tax Workbook 2015/16 is specially written to help students develop a solid understanding of tax principles and also gain practical knowledge of the Singapore tax system. This book is designed to
- provide concise introduction to Singapore tax essentials
- prepare students for taxation examinations
- develop a solid foundation for professional tax practice
This latest edition includes all the relevant legislative and administrative changes since the previous edition, including the intervening amendments to the Income Tax Act, Economic Expansion Incentives (Relief from Income Tax) Act, Goods and Services Tax Act and administrative developments up to 23 February 2015.