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The Resource Limiting base erosion, edited by Erik Pinetz, Erich Schaffer

Limiting base erosion, edited by Erik Pinetz, Erich Schaffer

Label
Limiting base erosion
Title
Limiting base erosion
Statement of responsibility
edited by Erik Pinetz, Erich Schaffer
Contributor
Editor
Subject
Language
eng
Summary
Présentation de l'éditeur : "Hybrid mismatch arrangements, CFC rules, transfer pricing rules: "Limiting Base Erosion", the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation."
Member of
Cataloging source
ZWZ
Illustrations
illustrations
Index
no index present
Literary form
non fiction
http://library.link/vocab/relatedWorkOrContributorName
  • Pinetz, Erik
  • Schaffer, Erich
Series statement
Series on international tax law
Series volume
volume 104
http://library.link/vocab/subjectName
  • International business enterprises
  • International business enterprises
Target audience
specialized
Label
Limiting base erosion, edited by Erik Pinetz, Erich Schaffer
Instantiates
Publication
Copyright
Bibliography note
Notes bibliogr
Content type code
txt
Content type MARC source
rdacontent
Contents
  • Purpose of and Policy Considerations for Implementing Hybrid Mismatch Rules, Linda Danicz; Limiting Base Erowion under National Law by a Hybrid Mismatch Rule for Financial Instruments, Luigi Polo Dimel; Limiting Base Erosion under National Law by a Hybrid Mismatch Rule for Disregarded Payments Made by a Hybrid Payer, Marek Rapant; Limiting Base Erosion under National Tax Law by a Hybrid Mismatch Rule for Reverse Hybrids, Tomasz Hatylak; Limiting Base Erosion under Tax Treaty Law by Includinig a Rule for Hybrid Entities in the OECD Model Convention, Silvia Hallova; Limiting Base Erosion under Tax Treaty Law by Including a Saving Clause in the OECD Model Convention, Gianluca D{u2019}Aula; Relationship between the Rules on Hybrid Mismatch Arrangements under National and International Law as well as under the National Laws of Different Jurisdiction, Janos Pasztor; Compatibility of the Proposal of the OECD on Neutralizing the Effects of Hybrid Mismatch Arrangements with EU Law, Costas Savva; Interaction of Hybrid Mismatch Rules with Other Areas of the BEPS Action Plan, Martin Calatrava; Purpose and Policy Considerations for Implementing CFC Rules, Wolfgang Riedl; Threshold Requirements for CFC Rules: Definition of Control, Tioga Sousa Seixas; Threshold Requirements for CFC Rules: Definition of Income, Thomas Pichler; Implementation of a CFC Rule: Rules to Compute and Attribute Income, Eva Palaticka; Implementation of a CFC Rule: Rules to Prevent or Eliminate Double Taxation, Martino Pinelli;
  • Controlled Foreign Company Rules and the EU, Julia de Jong; Purpose and Policy Considerations for Implementing Rules, Lino Lunardi; Implementation of an Interest Deduction Rule: Threshold for Application, Cecilia Stenberg; Compatibility with EU Law of Rules Limiting the Deductability of Interest and Other Financial Payments, Gabriele Colombaioni; Interaction of Rules Limiting the Deductability of Interest and Other Financial Payments with Other Areas of the BEPS Action Plan, Viktor Mitev; Limiting Base Erosion by Enhancing Transfer Pricing Documentation, Anja Liske; Limiting Base Erosion by Improving Transfer Pricing Rules on Location Savings, Nga Nguyen; Limiting Base Erosion by Improving Transfer Pricing Rules on Group Synergies for Multinational Enterprises, Luca Angiolilli; Limiting Base Erosion by Improving Transfer Pricing Rules on Assembled Workforces, Miroslava Vojtekova; Limiting Base Erosion by Improving Transfer Pricing Rules on Ownership, Development and Protection of Intangibles, Carlotta Mugnai; Unidentifiable Intangible Assets and their Transfer or Assignment in the Light of the Revised OECD Transfer Pricing Guidelines, Jan Kiss; Limiting Base Erosion by Improving Transfer Pricing Rules on Determining the Arm{u2019}s Length Conditions in Cases Involving Intangibles, Skeiv Licollari
Dimensions
23 cm.
Extent
1 volume (XVII-548 pages)
Isbn
9783707337587
Isbn Type
(br)
Media MARC source
  • rdamedia
  • isbdmedia
Media type code
  • n
  • n
Other control number
9783707337587
Other physical details
illustrations
System control number
(OCoLC)1031975270
Label
Limiting base erosion, edited by Erik Pinetz, Erich Schaffer
Publication
Copyright
Bibliography note
Notes bibliogr
Content type code
txt
Content type MARC source
rdacontent
Contents
  • Purpose of and Policy Considerations for Implementing Hybrid Mismatch Rules, Linda Danicz; Limiting Base Erowion under National Law by a Hybrid Mismatch Rule for Financial Instruments, Luigi Polo Dimel; Limiting Base Erosion under National Law by a Hybrid Mismatch Rule for Disregarded Payments Made by a Hybrid Payer, Marek Rapant; Limiting Base Erosion under National Tax Law by a Hybrid Mismatch Rule for Reverse Hybrids, Tomasz Hatylak; Limiting Base Erosion under Tax Treaty Law by Includinig a Rule for Hybrid Entities in the OECD Model Convention, Silvia Hallova; Limiting Base Erosion under Tax Treaty Law by Including a Saving Clause in the OECD Model Convention, Gianluca D{u2019}Aula; Relationship between the Rules on Hybrid Mismatch Arrangements under National and International Law as well as under the National Laws of Different Jurisdiction, Janos Pasztor; Compatibility of the Proposal of the OECD on Neutralizing the Effects of Hybrid Mismatch Arrangements with EU Law, Costas Savva; Interaction of Hybrid Mismatch Rules with Other Areas of the BEPS Action Plan, Martin Calatrava; Purpose and Policy Considerations for Implementing CFC Rules, Wolfgang Riedl; Threshold Requirements for CFC Rules: Definition of Control, Tioga Sousa Seixas; Threshold Requirements for CFC Rules: Definition of Income, Thomas Pichler; Implementation of a CFC Rule: Rules to Compute and Attribute Income, Eva Palaticka; Implementation of a CFC Rule: Rules to Prevent or Eliminate Double Taxation, Martino Pinelli;
  • Controlled Foreign Company Rules and the EU, Julia de Jong; Purpose and Policy Considerations for Implementing Rules, Lino Lunardi; Implementation of an Interest Deduction Rule: Threshold for Application, Cecilia Stenberg; Compatibility with EU Law of Rules Limiting the Deductability of Interest and Other Financial Payments, Gabriele Colombaioni; Interaction of Rules Limiting the Deductability of Interest and Other Financial Payments with Other Areas of the BEPS Action Plan, Viktor Mitev; Limiting Base Erosion by Enhancing Transfer Pricing Documentation, Anja Liske; Limiting Base Erosion by Improving Transfer Pricing Rules on Location Savings, Nga Nguyen; Limiting Base Erosion by Improving Transfer Pricing Rules on Group Synergies for Multinational Enterprises, Luca Angiolilli; Limiting Base Erosion by Improving Transfer Pricing Rules on Assembled Workforces, Miroslava Vojtekova; Limiting Base Erosion by Improving Transfer Pricing Rules on Ownership, Development and Protection of Intangibles, Carlotta Mugnai; Unidentifiable Intangible Assets and their Transfer or Assignment in the Light of the Revised OECD Transfer Pricing Guidelines, Jan Kiss; Limiting Base Erosion by Improving Transfer Pricing Rules on Determining the Arm{u2019}s Length Conditions in Cases Involving Intangibles, Skeiv Licollari
Dimensions
23 cm.
Extent
1 volume (XVII-548 pages)
Isbn
9783707337587
Isbn Type
(br)
Media MARC source
  • rdamedia
  • isbdmedia
Media type code
  • n
  • n
Other control number
9783707337587
Other physical details
illustrations
System control number
(OCoLC)1031975270

Library Locations

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      3400 Chestnut Street, Philadelphia, Pennsylvania, 19104, US
      39.954941 -75.193362
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