Evolution Of Apa Regime

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Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.

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Genre : Law
Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
Release : 2021-07-19
File : 252 Pages
ISBN-13 : 9789403535524


Taxation Planning For Middle East Operations

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If investment in the EEC countries has been the major preoccupation of the international business community in the 1960's, contracting in the Arab states seems to become one of the major trends of the 1970's. The need for multicountry business and tax information was felt simultane ously. Language difficulties, scarcity of legal and other sources, distance and, most of all, the novelty of business expansion in this direction made such information still more necessary than in the European or inter American setting. A few symposiums were held, corporate and tax laws were translated, research studies were initiated, among which the book of Mr and Mrs SIIILLING on Doing Business in Saudi Arabia and the Arab Gulf States, a rich mine of general business information. I was therefore very pleased when Mrs CLERIN, completing her tax studies at Ecole Superieure des Sciences Fiscales in Brussels, mentioned that she was going to live in the Middle East, had the opportunity to work with a well-known international accounting firm and proposed to focus her final dissertation at the School on the tax planning of operations in Arab countries. She devoted months of research to the study of sources both in Middle East and in industrial ized Western countries, to come up with a true planning study, clear, readable and practical. The description of the tax and corporate structure of the operating territories will be found in the first half of the book.

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Genre : Business & Economics
Author : Rose M. Clerin
Publisher : Springer
Release : 2013-12-01
File : 140 Pages
ISBN-13 : 9789401744775


Contemporary Research On Business And Management

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This book contains selected papers presented at the 4th International Seminar of Contemporary Research on Business and Management (ISCRBM 2020), which was organized by the Alliance of Indonesian Master of Management Program (APMMI) and held in Surubaya, Indonesia, 25-27 November 2020. It was hosted by the Master of Management Program Indonesia University and co-hosts Airlangga University, Sriwijaya University, Trunojoyo University of Madura, and Telkom University, and supported by Telkom Indonesia and Triputra. The seminar aimed to provide a forum for leading scholars, academics, researchers, and practitioners in business and management area to reflect on current issues, challenges and opportunities, and to share the latest innovative research and best practice. This seminar brought together participants to exchange ideas on the future development of management disciplines: human resources, marketing, operations, finance, strategic management and entrepreneurship.

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Genre : Technology & Engineering
Author : Siska Noviaristanti
Publisher : CRC Press
Release : 2021-11-25
File : 293 Pages
ISBN-13 : 9781000473261


Science For Governing Japan S Population

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A major new study tracing historical roots of the interplay between policy, population and science in Japan from the 1860s-1950s.

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Genre : Technology & Engineering
Author : Aya Homei
Publisher : Cambridge University Press
Release : 2022-11-17
File : 313 Pages
ISBN-13 : 9781009186834


International Economic Review

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Genre : Economics
Author :
Publisher :
Release : 2002-10
File : 48 Pages
ISBN-13 : UIUC:30112106553867


Who Owns Whom

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Genre : Corporations
Author :
Publisher :
Release : 2008
File : 2314 Pages
ISBN-13 : UCLA:L0074872458


Regionalism And Rivalry

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As Japan's newfound economic power leads to increased political power, there is concern that Japan may be turning East Asia into a regional economic bloc to rival the U.S. and Europe. In Regionalism and Rivalry, leading economists and political scientists address this concern by looking at three central questions: Is Japan forming a trading bloc in Pacific Asia? Does Japan use foreign direct investment in Southeast Asia to achieve national goals? Does Japan possess the leadership qualities necessary for a nation assuming greater political responsibility in international affairs? The authors contend that although intraregional trade in East Asia is growing rapidly, a trade bloc is not necessarily forming. They show that the trade increase can be explained entirely by factors independent of discriminatory trading arrangements, such as the rapid growth of East Asian economies. Other chapters look in detail at cases of Japanese direct investment in Southeast Asia and find little evidence of attempts by Japan to use the power of its multinational corporations for political purposes. A third group of papers attempt to gauge Japan's leadership characteristics. They focus on Japan's "technology ideology," its contributions to international public goods, international monetary cooperation, and economic liberalization in East Asia.

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Genre : Business & Economics
Author : Jeffrey A. Frankel
Publisher : University of Chicago Press
Release : 2007-12-01
File : 486 Pages
ISBN-13 : 9780226260242


Productivity International Comparisons Of Economic Growth

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These two volumes present empirical studies that have permanently altered professional debates over investment and productivity as sources of postwar economic growth in industrialized countries. The distinctive feature of investment is that returns can be internalized by the investor. The most straightforward application of this idea is to investments that create property rights, but these volumes broaden the meaning of capital formation to include investments in education and training. International Comparisons of Economic Growth focuses on comparisons among industrialized countries. Although Germany and Japan are often portrayed as economic adversaries of the U.S., postwar experiences in all three countries support policies that give high priority to stimulating and rewarding capital formation. In the Asian model of growth exemplified by Japan investments in tangible assets and human capital are especially critical during periods of rapid growth.

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Genre : Business & Economics
Author : Dale Weldeau Jorgenson
Publisher : MIT Press
Release : 1995
File : 516 Pages
ISBN-13 : 0262100509


Transnational Data Report

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Genre : Computer networks
Author :
Publisher :
Release : 1981
File : 438 Pages
ISBN-13 : UOM:39015019109217


Statistics Of Income

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Genre : Corporate profits
Author :
Publisher :
Release : 1991
File : 544 Pages
ISBN-13 : MINN:31951D00357116M