International and Cross-Border Taxation in New Zealand
Title | International and Cross-Border Taxation in New Zealand PDF eBook |
Author | Craig Macfarlane Elliffe |
Publisher | |
Pages | 765 |
Release | 2015 |
Genre | Double taxation |
ISBN | 9780864728999 |
International tax reform - Full imputation - Part 2 (Volume 1)
Title | International tax reform - Full imputation - Part 2 (Volume 1) PDF eBook |
Author | Consultative Committee on Full Imputation and International Tax Reform |
Publisher | The Treasury, New Zealand |
Pages | 224 |
Release | 1988-07-31 |
Genre | |
ISBN |
The final report of the Consultative Committee on Full Imputation and International Tax Reform. Volume 1 contains recommendations on the further detailed measures required for the operation of the imputation and international tax regimes. Volume 2 sets out the draft legislation.
Tax
Title | Tax PDF eBook |
Author | Leslie Prescott-Haar |
Publisher | |
Pages | 0 |
Release | 2020 |
Genre | Business enterprises, Foreign |
ISBN |
Cross-Border Taxation of Permanent Establishments
Title | Cross-Border Taxation of Permanent Establishments PDF eBook |
Author | Andreas Waltrich |
Publisher | Kluwer Law International B.V. |
Pages | 340 |
Release | 2016-04-20 |
Genre | Law |
ISBN | 9041168389 |
The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.
International Tax at the Crossroads
Title | International Tax at the Crossroads PDF eBook |
Author | Craig Elliffe |
Publisher | Edward Elgar Publishing |
Pages | 325 |
Release | 2023-12-11 |
Genre | Law |
ISBN | 180088902X |
In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.
International tax reform
Title | International tax reform PDF eBook |
Author | New Zealand. Consultative Committee on Full Imputation and International Tax Reform |
Publisher | |
Pages | |
Release | 1988 |
Genre | |
ISBN |
New Zealand's International Taxation
Title | New Zealand's International Taxation PDF eBook |
Author | Garth A. Harris |
Publisher | |
Pages | 476 |
Release | 1990 |
Genre | Business & Economics |
ISBN |
This book is an authoritative guide to two major aspects of the New Zealand tax system: the rules for taxing income received by its residents from overseas, and those for taxing income received by overseas residents from New Zealand.