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Guide to Global Real Estate Investment Trusts aims at a comprehensive analysis of the existing Real Estate Investment Trusts (REIT) regimes. The global listed property sector has been characterized by a variety of noteworthy developments over the recent past, the key being the proliferation of REIT-type structures in countries around the world. Despite an uncertain economic environment, REITs have proven their ability to promote institutional real estate investments in global financial markets. In light of this growing focus, this book provides a fundamental knowledge of the most important REIT legislations and an in-depth analysis on the regulatory and tax laws governing the REIT regime. What’s in this book: This book features on such topics and issues as: legal and tax underpinnings of REIT-friendly legislations; critical analyses on the tax treaties’ aspects of REITs, including OECD recommendations; structure and functioning of a REIT; REIT formation, operation and liquidation, mergers, acquisitions and dispositions; planning for public and private REIT offerings and re-securitizations. How this will help you: REITs are inherently complex, and their interplay with tax treaties further compounds the complexity. As a work that is updated regularly, this book helps investors, lawmakers and finance authorities to continuously monitor the evolution of the market and regulatory framework and thereby expand their knowledge of the REIT regimes that are undergoing constant change. Thus, this highly accessible yet authoritative work serves as the perfect decision-making tool for any professional looking for guidance on the challenges and opportunities REITs engender.
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’.
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.