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Taxation of Income from Domestic and Cross-border Collective Investment

Author : Andreas Oestreicher
Publisher : Springer Science & Business Media
Page : 170 pages
File Size : 21,8 MB
Release : 2013-07-30
Category : Law
ISBN : 3319004492

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The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.

Taxation of Cross-Border Portfolio Investment Mutual Funds and Possible Tax Distortions

Author : OECD
Publisher : OECD Publishing
Page : 172 pages
File Size : 45,95 MB
Release : 1999-05-04
Category :
ISBN : 9264172882

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This book analyses the taxation of cross-border portfolio investments by means of collective investment institutions. Possible tax distortions specific to the area of collective investment institutions are identified for a representative group of OECD countries.

Taxation of Cross-border Portfolio Investment

Author :
Publisher : Org. for Economic Cooperation & Development
Page : 184 pages
File Size : 28,97 MB
Release : 1999
Category : Business & Economics
ISBN :

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The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institution

Taxation of Investment Funds in the European Union

Author : Tomi Viitala
Publisher : IBFD
Page : 427 pages
File Size : 17,86 MB
Release : 2005
Category : Capital gains tax
ISBN : 9076078750

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The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.

International Tax

Author : Michael Honiball
Publisher : Siber Ink
Page : 908 pages
File Size : 46,49 MB
Release : 2011-03-15
Category : Business & Economics
ISBN : 1920025774

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This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.

Taxing Offshore Investment Income

Author : John Prebble
Publisher :
Page : 216 pages
File Size : 10,7 MB
Release : 2006
Category : Biography & Autobiography
ISBN :

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An international panel of experts address the design and operation of offshore investment fund regimes. The book is comparative, dealing with topics issue-by-issue rather than country-by-country. (Legal Reference/Law)

Taxation of Cross Border Income

Author : Klaus Vogel
Publisher : Springer
Page : 62 pages
File Size : 45,84 MB
Release : 1994-01-11
Category : Business & Economics
ISBN :

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This study discusses the issues involved in making an informed choice between the source principle and the domicile principle as the basis for allocating the corporate profits base.

The Taxation of Foreign Profits

Author : M. P. Devereux
Publisher :
Page : 32 pages
File Size : 37,38 MB
Release : 2015
Category : Corporations
ISBN :

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This paper synthesizes and extends the literature on the taxation of foreign source income in a framework that covers both greenfield and acquisition investment, and a general constraint linking investment at home and abroad for the multinational by introducing a cost of adjustment for the mobile factor. Unless the cost of adjustment is zero, the domestic tax on foreign-source income should always be set to ensure the optimal allocation of the mobile factor between domestic and foreign assets and should follow the classical rules in the literature; national optimality requires the deduction rule, and global optimality requires the credit rule. Only in the zero-cost case does exemption become optimal. Allowances can be set so as to ensure that domestic and foreign asset purchases are undistorted by the tax system: this requires a cash-flow tax on domestic investment in the greenfield case, and a cross-border cash flow tax on foreign investment in both cases. These basic results extend to various extensions of the model, notably (i) when a profit-shifting motive is present; (ii) to some extent, when a corporate income tax is in place. The introduction of tax administration costs into the model can explain the empirical trend towards use of the exemption regime.