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Substance in International Tax Law

DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

By: Florian Navisotschnigg

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Substance in International Tax Law

DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

By: Florian Navisotschnigg

The notion of ‘substance’ is proving to be central to the OECD’s base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership). In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions: What substance is necessary to be entitled to intangible-related returns? What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions? What substance is necessary to collect royalties free from withholding taxes? Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles. It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles.

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Page Count

233

Publisher

Kluwer Law International B.V.

Published Date

ISBN 10

940354905X

ISBN 13

9789403549057

Substance in International Tax Law

DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

By: Florian Navisotschnigg

Write a review Read reviews Take a Quiz Solve Book Puzzle

Substance in International Tax Law

DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

By: Florian Navisotschnigg

The notion of ‘substance’ is proving to be central to the OECD’s base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership). In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions: What substance is necessary to be entitled to intangible-related returns? What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions? What substance is necessary to collect royalties free from withholding taxes? Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles. It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles.

Average ratings

N/A

5

0%

4

0%

3

0%

2

0%

1

0%

Solve jigsaw puzzle

Age

Page Count

233

Publisher

Kluwer Law International B.V.

Published Date

ISBN 10

940354905X

ISBN 13

9789403549057