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Substance in International Tax Law: DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

Substance in International Tax Law: DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

作者： Florian Navisotschnigg
出版商： Kluwer Law International
ISBN: 9789403548951
出版时间 August 2022
规格： Hardback
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

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详细
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.
CHAPTER 1

Setting the Scene

CHAPTER 2

Substance in the Area of Transfer Pricing: DEMPE Approach

CHAPTER 3

Substance in the Area of Harmful Tax Practices: Substantial Activity Requirement

CHAPTER 4

Substance in the Area of Tax Treaties: Beneficial Ownership

CHAPTER 5

Comparison Between DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

CHAPTER 6

Conclusions

Bibliography

Index

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