The OECD's guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.
Key features include:
Practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment
Chapters that explore specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and Commentary
Explanation of how BEPS treaty rules affect a range of corporate tax strategies including: permanent establishment, use of corporate vehicles and intra-group transactions
Information on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement.
Providing a succinct and practical approach to the topic, this book will be an insightful resource for those practising in the field of international taxation as well as corporate in-house counsel. Researchers and students seeking clear information on BEPS and its real world application affecting tax treaties will also benefit from this concise guide.
Rezensionen / Stimmen
'Garbarino offers his deep knowledge in international tax systems to explain the new international tax planning thresholds. Changes of tax treaty standards derived from the BEPS Project especially, those reflected in the 2017 OECD Model/Commentary offer a basis for insightful guidance from the perspective of the country of destination of the investment. Garbarino analyses the test of the permanent establishment and treaty entitlement and encompasses rules related to corporate vehicles. Investors and their tax advisors, public authorities (including tax judges) and academics will find excellent guidance for their activities in this new international tax scenario.'
--Luis Eduardo Schoueri, University of Sao Paulo and the Brazilian Tax Law Institute, Brazil
Sprache
Verlagsort
Zielgruppe
Maße
Höhe: 244 mm
Breite: 169 mm
ISBN-13
978-1-78897-688-6 (9781788976886)
Copyright in bibliographic data and cover images is held by Nielsen Book Services Limited or by the publishers or by their respective licensors: all rights reserved.
Schweitzer Klassifikation
Carlo Garbarino, Full Professor of International Taxation, Department of Legal Studies, Bocconi University and Director of Osservatorio Fiscale, SDA Bocconi School of Management, Milano, Italy
Contents: 1. Doing Business Through a Permanent Establishment (PE) 2. Entitlement to Tax Treaties 3. Doing Business Through Corporate Vehicles 4. Dispute Settlement and Enforcement Index
