Book
Limits to Tax Planning
This collection of master theses analyses various measures and aspects of tax planning, such as corporate residence, the set-up of partnerships and holding companies, transfer pricing, and the shopping into tax treaties, specific tax treaty rules and EU Directives. The main focus of this book lies on countermeasures to tax planning: CFC rules, thin cap rules, interest barrier rules and tax collection at withholding are examined as examples for national measures. The tax treaty law measures presented in this book include mutual assistance, limitation on benefits, subject-to-tax and activity clauses, the beneficial ownership concept, as well as anti-abuse rules of specific allocation rules. Within the EU, anti-tax planning measures must respect Union law, which includes the fundamental freedoms, as well as provisions of secondary EU law, such as the Savings, Merger, Parent-Subsidiary and Interest and Royalty Directive, but also the harmonized area of indirect taxes and the CCCTB.
Detail Information
Call Number |
07 LIM kar
|
---|---|
Publisher | Linde Verlag : Wien., 2013 |
Collation |
624p.; 22.5cm
|
Language |
English
|
Classification |
07 LIM kar
|
ISBN/ISSN |
978-3-7073-2408-2
|
Edition |
Series on International Tax Law
|
Subject(s) |