Intertax最新文献_第9页

Critical Review Of The ATAD Implementation: The Implementation of the ATAD in Greece ATAD实施情况的批判性回顾：希腊的ATAD实施

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022061

K. Perrou

引用次数: 0

Article: A European Internet Access Tax 文章:欧洲互联网接入税

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022059

José A. Rozas, J. Pownall

{"title":"Article: A European Internet Access Tax","authors":"José A. Rozas, J. Pownall","doi":"10.54648/taxi2022059","DOIUrl":"https://doi.org/10.54648/taxi2022059","url":null,"abstract":"The OECD’s plans to address the challenges posed by the digitalization of the economy are progressing towards a complex system. The work of this international organization is based on two pillars – reallocation of rights and global minimum taxation on corporate profits – which should lead to the adoption of a common international model. Its outcome is uncertain; however, its implementation could require a significant amount of reliable information on the size and territorial distribution of the digital market.\u0000This purpose – the configuration of a digital tax census – could be fulfilled by the introduction of a European internet access tax that is a registration tax. Its taxpayers would be the holders of network access rights through telecommunication infrastructures located in the EU territory, and the service providers would function as substitutes for the taxpayers with the right – but not the obligation – to pass on the tax debt to the user. It would necessarily have to be a reduced tax with the objective of census purposes and a tax period of no less than three months. Based on a Catalan experience, which was unsuccessful due to its scope and characteristics, this article explores its possible implementation in the EU, within the framework of the search for solutions to the tax challenges posed by the digitalization of the economy.\u0000Digital taxation, internet access, European taxation, EU budget, EU own resources, EU fiscal policy, EU tax harmonization, EU taxation, EU tax harmonization.","PeriodicalId":45365,"journal":{"name":"Intertax","volume":" ","pages":""},"PeriodicalIF":0.6,"publicationDate":"2022-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45692455","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Article: A Study on the Protection of Taxpayer Rights in an Era of Enhanced Exchange of Information: How Can the Chinese Approach Be Improved? 文章:信息交流时代纳税人权利保护研究:中国方式如何改进?

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022058

Bart Peeters, Zhe Chen

引用次数: 0

Literature Review: Addressing Tax Arbitrage With Hybrid Financial Instruments. A Multidisciplinary Study and Proposal for Developed and Developing Countries, M. Scherleitner. Amsterdam: IBFD. 2020. 文献综述:用混合金融工具解决税收套利问题。发达国家与发展中国家的多学科研究与建议，谢雷特纳。阿姆斯特丹:IBFD。2020.

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022064

Niels Bammens

引用次数: 0

Tax In History: Rome Double Tax Convention: The First Multilateral Treaty for the Purpose of Avoiding Double Taxation 历史上的税收:《罗马避免双重征税公约》:第一个旨在避免双重征税的多边条约

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022062

D. Popović, Svetislav V. Kostić

{"title":"Tax In History: Rome Double Tax Convention: The First Multilateral Treaty for the Purpose of Avoiding Double Taxation","authors":"D. Popović, Svetislav V. Kostić","doi":"10.54648/taxi2022062","DOIUrl":"https://doi.org/10.54648/taxi2022062","url":null,"abstract":"This paper presents the story of the world’s first multilateral double taxation treaty, a treaty concluded in Rome after the end of World War I by all the successor states of former Austria-Hungary with the exception of Czechoslovakia. On the centennial of this treaty the authors first present its historical, legal and economic background and attempt to determine which of the quite few already existing double taxation treaties served as the model for a document which preceded the work done under the auspices of the League of Nations on the topic of double taxation. Concluding that it was the 1899 Austria-Hungary/Prussia double taxation treaty which served as inspiration for the drafters of the 1922 Rome double tax convention, the authors continue to analyse and compare their individual provisions. Subsequently, the authors turn to the question of why this multilateral treaty never came into force and present interesting historical data found in the archives of Yugoslavia. In the end, the authors conclude that the tale of the Rome double taxation convention reminds us in our modern environment about the values of common sense even in adverse political circumstances and clearly shows that multilateralism should not be abandoned as a prospective option.\u0000Multilateral convention, double taxation, World War I, League of Nations, Austria-Hungary, source, residence.","PeriodicalId":45365,"journal":{"name":"Intertax","volume":" ","pages":""},"PeriodicalIF":0.6,"publicationDate":"2022-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48231356","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Policy Note: Tax Transparency Is Here to Stay: An Analysis of the Public CbCR Directive 政策说明:税收透明度将继续存在:对公共CbCR指令的分析

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022060

Willemien Netjes, D. Freyer

{"title":"Policy Note: Tax Transparency Is Here to Stay: An Analysis of the Public CbCR Directive","authors":"Willemien Netjes, D. Freyer","doi":"10.54648/taxi2022060","DOIUrl":"https://doi.org/10.54648/taxi2022060","url":null,"abstract":"On 21 December 2021, the ‘Public CbCR Directive’ entered into force. According to this new directive, companies within its scope will have to publish a public country-by-country report including income tax information for each European Union Member State where the company has a presence. Whereas most companies in scope already prepared such a report, until now this was shared only with tax authorities for the purpose of enabling a high-level tax risk assessment. On the contrary, the new directive requires companies to publish the tax information on their website in order to be shared with investors, civil society and the general public.\u0000Ahead of this directive however, it can be witnessed that an increasing number of companies is already publishing tax information on a voluntary basis, despite the fact that publishing such information can lead to greater scrutiny and can potentially harm a company´s reputation. This contribution is a formal discourse of how the Public CbCR Directive initiative is a logical consequence of years of corporate tax transparency discussions and how it fits into broader global environmental, social, and governance (ESG) trends.\u0000Corporate tax, tax transparency, ESG, Directive (EU) 2021/2101, Public CbCR, country-by-country, transfer pricing, CbCR, tax avoidance, transparency.","PeriodicalId":45365,"journal":{"name":"Intertax","volume":" ","pages":""},"PeriodicalIF":0.6,"publicationDate":"2022-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41681440","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Case Law Trend: The Question of Interaction Between the Tax and Criminal Proceedings in the ECtHR Case-Law 判例法走向：ECtHR判例法中的税务与刑事诉讼互动问题

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022063

Barış Bahçeci, Demirhan Burak Çelik

{"title":"Case Law Trend: The Question of Interaction Between the Tax and Criminal Proceedings in the ECtHR Case-Law","authors":"Barış Bahçeci, Demirhan Burak Çelik","doi":"10.54648/taxi2022063","DOIUrl":"https://doi.org/10.54648/taxi2022063","url":null,"abstract":"This objective of this study is to analyse the definition and the application of the concept of sufficiently close in substance and in time by the European Court of Human Rights (ECtHR) in terms of tax penalties. The Court implements this concept in Article 4 of the Protocol Number 7 of the European Convention on Human Rights (ECHR) and intends to regulate the interaction between the two sets of (tax and criminal) procedures that deal with the penalization of the same matter. The progress of the case law is examined from the Glantz and Nykänen judgments in 2014 and the Kristjansson judgment in 2021. Two research questions are addressed: What is the connection in substance, and what is the connection in time? For the first question, the case law points out that the connection in substance requires the repetition in collection evidence. However, the boundaries of the relationship that should be established between the two sets of proceedings are uncertain and debatable. For the second question, the temporal connection has not yet been defined in case law, and its application overlaps with the scope of the right to a fair trial. Thus, it is seen that the boundaries in the both contexts need to be redrawn in order to eliminate the current ambivalence.\u0000ECtHR case-law, interaction between proceedings, connection in substance, connection in time, ne bis in idem, tax penalty, tax procedure, right to a fair trial.","PeriodicalId":45365,"journal":{"name":"Intertax","volume":" ","pages":""},"PeriodicalIF":0.6,"publicationDate":"2022-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45796333","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Literature Review: Is There Finally an International Tax System?, W. Schön. Vol. 13(3). World Tax Journal. Amsterdam: IBFD. 2021. 文献综述：终于有国际税收制度了吗？，W.Schön。第13卷（3）。《世界税务杂志》。阿姆斯特丹：IBFD。2021

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022065

Elizabeth Gil García

引用次数: 0

Editorial: Human Rights and the Two-Pillar Solution 社论:人权与双支柱解决方案

IF 0.6

Intertax Pub Date : 2022-07-01 DOI: 10.54648/taxi2022066

Philip Baker

引用次数: 0

Article: The Fundamental Freedoms and the Taxation of Dividends Received by Non-resident Investment Funds: Some Thoughts on Non-discrimination With a Special Focus on Recent ECJ Case Law 文章：非居民投资基金股息的基本自由和税收：关于非歧视的一些思考，特别是最近的欧洲法院判例法