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In light of the significant transformations affecting international tax in recent years, this book provides an in-depth assessment of the key issues impacting 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 at the Crossroads examines the overarching aspects of international tax reform, evaluates the IF’s proposed multilateral tax reforms and outlines the alternative unilateral options available and their subsequent legal consequences. Chapters analyse whether proposed tax reforms are stable, who should be involved in formulating international tax policy, who is influencing international tax policy, and the options and issues which arise in the event that multilateral compromise does not work.This insightful book will prove an essential read for students, academics and researchers interested in domestic and international tax law, commercial law and fiscal policy. It will also be of benefit to advisors, administrators, practitioners and officials working in the financial sector.
Edited by Craig Elliffe, Faculty of Law, University of Auckland, New Zealand
Contents:Preface ixIntroduction: standing at the crossroads 1Craig Elliffe and Matt Andrew1 Robustness and resilience in international tax reform 21Wolfgang Schön2 The reform of the institutional structure of international taxation 49Philip Baker KC3 Unilateralism and multilateralism in international tax 71Reuven Avi-Yonah4 Stability of the international tax system in a changing world 95Victoria Plekhanova and Chris Noonan5 Tax states, jurisdiction and the multilateral reality 115Miranda Stewart6 The impact of the global minimum tax on tax competition 142Michael Devereux and John Vella7 Is the shift to taxation at the point of destination inexorable? 167Matt Andrew and Richard Collier8 Multilateral tax reform 194Michael Littlewood9 Arbitration of tax disputes after the BEPS Two Pillar Solution 222Chris Noonan and Victoria Plekhanova10 The Canadian Digital Services Tax 246Wei Cui11 Legal problems with digital taxes in the United States and Europe 266Ruth Mason12 Data as a tax base 288Alison Pavlovich