Mli Made Easy - Couverture rigide

Sharma, Kuldeep

Couverture rigide

ISBN 10 : 9403532602 ISBN 13 : 9789403532608

Editeur : Kluwer Law International, 2021

Synopsis

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy<\/em> makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self\-contained book offers an unmatched article\-by\-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply.<\/p>

• Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in\-depth discussion of the following and more:<\/li>
• how specific gaps in existing bilateral tax treaties are addressed by the MLI;<\/li>
• positions taken by selected jurisdictions and their impact on treaties;<\/li>
• compatibility clauses, notification clauses, opting\-in mechanisms, alternative provisions, and reservations;<\/li>
• experiences in the course of implementation of the MLI;<\/li>
• misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI;<\/li>
• interaction between the principal purpose test and simplified limitation on benefits;<\/li>
• improving dispute resolution; and<\/li>
• meaning of the phrases \x26lsquo;on or after\x26rsquo;, \x26lsquo;other taxes\x26rsquo;, and interpretational issues in entry into effect provisions.<\/li> <\/ul>

  Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy\-to\-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.\x26nbsp;<\/p>

A propos du livre

À propos de l'auteur

Kuldeep Sharma, an erstwhile officer of the Indian Revenue Service, has worked for over thirty years in the Income Tax Department, wherein he has had the opportunity to work at multiple levels in Direct Taxes, i.e. in field dispensations, as well as, tax policy department under the aegis of Central Board of Direct Taxes (CBDT) and has garnered wide experience in taxation of corporates and non-corporates (including individuals). The last ten years of his service have been completely dedicated to the field of International Taxation and Transfer Pricing (IT&TP), wherein he has accredited himself in a variety of roles, involving Transfer Pricing (TP) audits, processing of Advance Pricing Agreements or Advance Pricing Arrangements (APAs). For four years, he has worked in the Foreign Tax and Tax Research Division of CBDT, wherein, apart from handling policy issues related to non-residents, Country-by-Country Reporting, Tax Treaty Negotiations and Complex APA, Mutual Agreement Procedure (MAP) cases, he has been actively engaged in matters involving Base Erosion and Profit Shifting (BEPS) and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Kuldeep Sharma holds BSc (Physics) Hons. as well as an MBA (Finance). His years of practical experiences in Direct Taxes have enabled him to successfully achieve the status of ADIT Graduate accredited by the Chartered Institute of Taxation, UK.

Détails de l'édition

• Éditeur: Kluwer Law International
• Date d'édition: 2021
• Langue: anglais
• ISBN 10: 9403532602
• ISBN 13: 9789403532608
• Reliure: Relié
• Nombre de pages: 400
• Coordonnées du fabricant: non disponible
• Personne responsable: non disponible