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Breaking BEPS : The New International Tax Diplomacy
Grinberg, Itai - 2017
International tax avoidance by multinational corporations is now front-page news. In a time of public austerity, citizens and legislators around the world have focused on the erosion of the corporate income tax base. In response, in 2012 the G-20 — the gathering of the leaders of the world's...
Persistent link: https://www.econbiz.de/10012971134
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Anti-Avoidance and Tax Treaty Policies in the Asian Pacific Region
Prebble QC, John - 2015
A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...
Persistent link: https://www.econbiz.de/10013038963
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Anti-Avoidance and Tax Treaty Policies and Practice in Asia and the Pacific
Prebble KC, John - 2015
A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...
Persistent link: https://www.econbiz.de/10014190782
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Extending taxation of interest and royalty income at source : an option to limit base erosion and profit shifting?
Finke, Katharina; Fuest, Clemens; Nusser, Hannah; … - 2014
This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...
Persistent link: https://www.econbiz.de/10010416288
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Do Chinese Income Taxes Qualify for the U.S. Foreign Tax Credit?
Pomp, Richard; Gelatt, Timothy; Surrey, Stanley - 2021
is a serious concern for foreign countries. For example, in China authorities have expressed a willingness to pursue a … levied on the income of a foreign corporation from which it receives dividends.This article looks at two taxes that China … stay. The JVITL taxes joint ventures operating in China on their world-wide income derived from production, business, and …
Persistent link: https://www.econbiz.de/10013212630
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Foreign Administrative Law and International Taxation : a Case Study of Tax Treaty Implementation in China
Cui, Wei - 2021
emanate from tax treaty implementation in China. In these cases, U.S. (and other foreign) investors face certain rules that …. The question arises as to whether U.S. taxpayers should contest such rules in China. Equally, the IRS faces the question …
Persistent link: https://www.econbiz.de/10013236614
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Tax Sparing Clauses as a Policy Instrument of Developing Countries and Their Descent : Evidence from the Latin-American Tax Treaty Network
Navarro, Aitor - 2020
Developing countries frequently grant corporate income tax incentives to attract foreign direct investment that would ultimately contribute to their economic growth. To secure the effectiveness of these measures at a cross-border level in the context of jurisdictions that eliminate double...
Persistent link: https://www.econbiz.de/10012826284
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Partial Repeal of Foreign Tax Credits by the Tax Cuts and Jobs Act : Resulting Behavioral Incentives, Self-Help, and New Mechanics for Some Remaining Portions of the Credit
Rosenberg, Rebecca - 2018
The new Tax Cuts and Jobs Act repeals approximately one-third of the foreign tax credit system. (The foreign tax credit generally reduces U.S. tax by the amount of the U.S. taxpayer's foreign income taxes, subject to many requirements.) Essentially, partial repeal will make it much harder to...
Persistent link: https://www.econbiz.de/10012910606
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Judging the New International Tax Regime : Testimony Before the U.S. Senate Committee on Finance
Kysar, Rebecca M. - 2018
The 2017 tax law made significant changes to the way the United States taxes multinational corporations on their cross-border income. The new legislation has, however, failed to solve old problems in the international system and also opened the door to new ones.The serious problems created, or...
Persistent link: https://www.econbiz.de/10012920203
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Permanent establishment as a foreign direct investment in Poland : identification of tax barriers in the context of new tax development
Jamrozy, Marcin; Janiszewska, Magdalena - In: International journal of management and economics 57 (2021) 2, pp. 177-193
The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting...
Persistent link: https://www.econbiz.de/10012606701