Bøger i Cambridge Tax Law Series serien

The question of how to tax multinational companies that operate highly digitalised business models is one of the most contested areas of international taxation. The tax paid in the jurisdictions in which these companies operate has not kept pace with their immense growth and the OECD has proposed a new international tax compromise that will allocate taxing rights to market jurisdictions and remove the need to have a physical presence in the taxing jurisdictions in order to sustain taxability. In this work, Craig Elliffe explains the problems with the existing international tax system and its inability to respond to challenges posed by digitalised companies. In addition to looking at how the new international tax rules will work, Elliffe assesses their likely effectiveness and highlights features that are likely to endure in the next waves of international tax reform.

"More than an introduction, this book challenges the reader to think about tax issues conceptually and holistically. Illustrated with practical examples, it will be useful to postgraduate students and junior practitioners, as well as to senior tax practitioners and academics who want to refresh their basic understanding of tax issues"--

"The United Nations in Global Tax Coordination fills the decade-long knowledge gap in international tax history concerning the UN Fiscal Commission that functioned as the overarching fiscal authority in the early years of the post-World War II economic order. With insights from political economy and international relations scholarship, this critical archival examination presents the story of tenacious activism by post-colonial developing countries to preserve source taxation rights and by the UN Secretariat in championing the development of equitable tax rules - activism that would lead developed countries to oust the UN as a forum for international tax norm setting. The book includes a revealing prehistory of the wartime work of the League of Nation's Princeton Mission that questions the legitimacy of the Mexico Model, the first model tax convention between developed and developing countries. This expertly researched work offers new knowledge that is essential reading on the roles of politics, states, secretariats, and private actors in directing global tax coordination. Nikki Jern-li Teo is a post-doctoral research affiliate at the University of Sydney"--

This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

This is an essential book for academics, practitioners and government officials interested in EU corporate tax law and international tax law. Christiana HJI Panayi provides an in-depth analysis of a number of tax issues affecting companies in the EU and reviews some of the high-profile debates in this area.

Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

Offers a theoretical framework for current international tax policy discussions. Criticising past and present co-operative initiatives, this book embraces structured competition as promoting efficiency and global justice. International tax scholars, policymakers, teachers and students are provided with a coherent vocabulary for the pressing policy issues at stake.

This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please.

A tax expenditure is a 'tax break' allowed to a taxpayer or group of taxpayers, for example, by way of concession, deduction, deferral or exemption. The tax expenditure concept, as it was first identified, was designed to demonstrate the similarity between direct government spending on the one hand and spending through the tax system on the other. The identification of benefits provided through the tax system as tax expenditures allows analysts to consider the fiscal significance of those parts of the tax system which do not contribute to the primary purpose of raising revenue. Although a seemingly simple concept, it has generated a range of complex definitional and practical issues, and this book identifies and critically assesses the controversial aspects of tax expenditure and tax expenditure management.

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

This book was first published in 2006. Many common law countries inherited British income tax rules. Whether the inheritance was direct or indirect, the rationale and origins of some of the central rules seem almost lost in history. Commonly, they are simply explained as being of British origin without more, but even in Britain the origins of some of these rules are less than clear. This book traces the roots of the income tax and its precursors in Britain and in its former colonies to 1820. Harris focuses on four issues that are central to common law income taxes and which are of particular current relevance: the capital/revenue distinction, the taxation of corporations, taxation on both a source and residence basis, and the schedular approach to taxation. He uses an historical perspective to make observations about the future direction of income tax in the modern world.

This book integrates legal, economic, and administrative materials about value added tax. Its principal purpose is to provide comprehensive teaching tools - laws, cases, analytical exercises, and questions drawn from the experience of countries and organizations from all areas of the world. It also serves as a resource for tax practitioners and government officials that must grapple with issues under their VAT or their prospective VAT. The comparative presentation of this volume offers an analysis of policy issues relating to tax structure and tax base as well as insights into how cases arising out of VAT disputes have been resolved. The authors have expanded the coverage to include new VAT related developments in Europe, Asia, Africa and Australia. A chapter on financial services has been added as well as an analysis of significant new cases.

Recounts the forgotten early development of the federal income tax in the United States. Topics covered range from marriage, to capital losses, to withholding. This book will be of particular interest to tax academics and professionals, but also to anyone wondering how income tax achieved its current form.

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. It will facilitate the work of courts, tax administrations, practitioners and scholars around the world.

This book explores how within less than 50 years the value-added tax (VAT) has risen to become one of the world's most dominant revenue instruments. It combines policy and legal analysis to propose a new way of understanding this rise so as to better reflect the realities of the VATs that are actually implemented.

Antony Ting critically analyses and compares alternative policy options adopted in eight countries with respect to ten key structural elements of a consolidation regime. This is the first comprehensive comparative study across a broad geographical spectrum and provides valuable information to countries contemplating the introduction of a new consolidation regime.

This book is not just for tax and public finance specialists, but for anyone interested in the development of the British and American corporation over the last century, the impact of law, politics, economics and culture on corporate taxation, and the effect of globalization in breaking down national distinctions.

This book explains transfer pricing through a global study of disputes and the implications of innovative dispute resolution methods. It discusses twenty representative jurisdictions and analyses multiple transfer pricing disputes from North and South America, Europe, Asia and Africa, including all four BRIC countries.

Including thirty-seven country reports from five continents, this book starts a global debate on bilateral tax treaties and ascertains how much the UN and OECD models affect the clauses of bilateral treaties. It is an essential tool for academics, practitioners and tax authorities.

Employing a range of theoretical approaches, and grounding its investigations in sociological theory and cultural philosophy, Ann Mumford provides the foundation for a comparative, contextual consideration of the issues that arise at the intersection of women, tax policy and the law.

Under the new economic and social conditions of the nineteenth century, governments began to undermine the law safeguarding the imposition and administration of taxes. This book traces the development, re-evaluation and subsequent recasting of the safeguards, which, though diminished, proved sufficiently robust to provide an enduring protection to the taxpayer.