Evaluating Canada S Attempt To Reconcile General Transfer Pricing Rules And Specific Antiabuse Provisions
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The Transfer Pricing Law Review
Author | : Steve Edge,Dominic Robertson |
Publsiher | : Unknown |
Total Pages | : 0 |
Release | : 2023 |
Genre | : Electronic Book |
ISBN | : 1804491780 |
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Canada U S Tax Treaty
Author | : Anonim |
Publsiher | : Unknown |
Total Pages | : 52 |
Release | : 1981 |
Genre | : Capital gains tax |
ISBN | : STANFORD:36105043817480 |
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Introducing a General Anti Avoidance Rule GAAR
Author | : Mr.Christophe J Waerzeggers,Mr.Cory Hillier |
Publsiher | : International Monetary Fund |
Total Pages | : 12 |
Release | : 2016-01-31 |
Genre | : Business & Economics |
ISBN | : 9781513515823 |
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Tax avoidance continues to attract attention globally with strong support for tax law reform at all levels. This Tax Law IMF Technical Note focuses on some of the key design and drafting considerations of one specific legal instrument (being, a statutory general anti-avoidance rule (GAAR)) which is often considered by authorities to combat unacceptable tax avoidance practices. A GAAR is typically designed to strike down those otherwise lawful practices that are found to be carried out in a manner which undermines the intention of the tax law such as where a taxpayer has misused or abused that law. However, the objective of combating unacceptable tax avoidance can itself make the legal design of a GAAR complex. This is simply because the phrase “tax avoidance” means different things to different people. Whatever the form of a GAAR, it should give effect to a policy that seeks to strike down blatant, artificial or contrived arrangements which are tax driven. However, the GAAR should be designed and applied so as not to inhibit or impede ordinary commercial transactions. This Tax Law IMF Technical Note discusses and explores how drawing a line between those arrangements which should be caught by the GAAR is a matter of degree and can be delicate.
Transactional Adjustments in Transfer Pricing
Author | : Aitor Navarro |
Publsiher | : Unknown |
Total Pages | : 135 |
Release | : 2017 |
Genre | : Electronic Book |
ISBN | : 9087224354 |
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Harmful Tax Competition An Emerging Global Issue
Author | : OECD |
Publsiher | : OECD Publishing |
Total Pages | : 84 |
Release | : 1998-05-19 |
Genre | : Electronic Book |
ISBN | : 9789264162945 |
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Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
The Tax Disputes and Litigation Review
Author | : Simon Whitehead |
Publsiher | : Unknown |
Total Pages | : 366 |
Release | : 2019 |
Genre | : Dispute resolution (Law) |
ISBN | : 1838620079 |
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OECD G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports
Author | : OECD |
Publsiher | : OECD Publishing |
Total Pages | : 20 |
Release | : 2016-08-26 |
Genre | : Electronic Book |
ISBN | : 9789264263437 |
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Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.
Protocol Amending 1980 Tax Convention with Canada
Author | : Canada |
Publsiher | : Unknown |
Total Pages | : 70 |
Release | : 2008 |
Genre | : Double taxation |
ISBN | : UCR:31210021301583 |
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