Substance in International Tax Law
By:Florian Navisotschnigg
Published on 2022-08-09 by
The notion of 'substance' is proving to be central to the OECD's base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles.
In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership).
In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions: What substance is necessary to be entitled to intangible-related returns? What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions? What substance is necessary to collect royalties free from withholding taxes? Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles.
It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles.
This Book was ranked at 122 by Google Books for keyword International Taxes.
Book ID of Substance in International Tax Law's Books is XQldzwEACAAJ, Book which was written by "Florian Navisotschnigg" have ETAG "E3aDaZjB9ZE"
Book which was published by since 2022-08-09 have ISBNs, ISBN 13 Code is 9789403548951 and ISBN 10 Code is 9403548959
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