当前货币:HKD

您的购物车中没有商品。

The OECD’s Global Minimum Tax and its Implementation in the EU: A Legal Analysis of Pillar Two in the Light of Tax Treaty and EU Law

The OECD’s Global Minimum Tax and its Implementation in the EU: A Legal Analysis of Pillar Two in the Light of Tax Treaty and EU Law

  • 作者:
  • 出版商: Kluwer Law International
  • ISBN: 9789403532875
  • 出版时间 October 2023
  • 规格: Hardback
  • 适应领域: Netherlands ? 免责申明:
    Countri(es) stated herein are used as reference only

List Price: S$258.14

S$250.39 Save S$7.74 (3%)

发货时间:大约 4-5 weeks
Extra 2-10 working days if shipping address outside Hong Kong
Free delivery Hong Kong?
Hong Kong: free delivery (order over HKD 1000)
  • 描述 
  • 大纲 
  • 详细

    The OECD’s Global Minimum Tax and Its Implementation in the EU is a book that aims to elucidate the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and endeavours to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties, and the EU’s recently adopted GloBE-Directive. Seldom in the history of international tax law have there been so many evolutions in such a short space of time: in a dizzying array of reports, work programs, consultations, and announcements, the OECD, with the active support of the EU, has developed a framework for a global minimum tax (Pillar Two or GloBE). Meanwhile, jurisdictions face practical difficulties incorporating an incredibly complex set of rules into their domestic legal systems.

    What’s in this book:

    The author analyses Pillar Two from a technical and a policy perspective and also provides for a thorough examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also comprises illustrative examples and pragmatic solutions to a myriad of technical and policy issues of Pillar Two. Among the seminal matters covered are the following:

    • History and Background of the global minimum tax discussion
    • Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR
    • Tax policy implications and deficiencies of the final design of Pillar Two
    • The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties
    • The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive
    • The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms

    How this will help you:

    In-depth comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive shed light on the common points and deviations. Besides comprehensive technical considerations, the book provides a broad tax policy perspective on the global minimum tax. For its matchless clarification of the issues alone, this book will be highly appreciated by practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two.

  • List of Figures
    List of Tables
    List of Abbreviations and Acronyms
    Preface and Acknowledgements
    CHAPTER 1. Introduction
    CHAPTER 2. Procedure of the Examination and Methods Applied
    CHAPTER 3. Background of Discussion Around a Minimum Tax Regime: From E-Commerce Via BEPS to the
    CHAPTER 4. The Technical Design of the GloBE Model Rules and Their Implementation in the GloBE-Directive
    CHAPTER 5. The GloBE Model Rules and the GloBE-Directive and Their Relation to Tax Treaties and Other Sources of Public International Law
    CHAPTER 6. The GloBE-Directive Within the EU’s Legal Order
    CHAPTER 7. Conclusions

    Bibliography
    OECD Reports and Policy Notes
    Table of Cases
    Table of Treaties and Models
    Table of EU Official Documents and Reports of EU Institutions

你可能需要

The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition)
The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition)

List Price: S$90.95

S$88.22 Save S$2.73 (3%)

Hong Kong Tax & Accounting Practical Toolkit (Basic Package)
Hong Kong Tax & Accounting Practical Toolkit (Basic Package)
S$618.63
Hong Kong Company Secretary Checklist, 2nd Edition
Hong Kong Company Secretary Checklist, 2nd Edition

List Price: S$234.60

S$227.56 Save S$7.04 (3%)

Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book)
Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book)

List Price: S$595.00

S$577.15 Save S$17.85 (3%)

Butterworths Hong Kong Discrimination Law Handbook, 4th Edition
Butterworths Hong Kong Discrimination Law Handbook, 4th Edition

List Price: S$255.00

S$247.35 Save S$7.65 (3%)

Sentencing in Hong Kong, 11th Edition
Sentencing in Hong Kong, 11th Edition

List Price: S$608.60

S$590.34 Save S$18.26 (3%)

Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 6th Edition
Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 6th Edition

List Price: S$387.60

S$375.97 Save S$11.63 (3%)

Butterworths Hong Kong Company Law Handbook, 26th Edition
Butterworths Hong Kong Company Law Handbook, 26th Edition

List Price: S$748.00

S$725.56 Save S$22.44 (3%)

Cross-Border Crime in Hong Kong: Extradition, Mutual Assistance & Financial Sanctions, 3rd Edition
Cross-Border Crime in Hong Kong: Extradition, Mutual Assistance & Financial Sanctions, 3rd Edition

List Price: S$353.60

S$342.99 Save S$10.61 (3%)

Clough & Clough on Personal Injuries
Clough & Clough on Personal Injuries

List Price: S$255.00

S$247.35 Save S$7.65 (3%)

Hong Kong Personal Insolvency Manual, 3rd Edition
Hong Kong Personal Insolvency Manual, 3rd Edition

List Price: S$340.00

S$329.80 Save S$10.20 (3%)

Butterworths Hong Kong Conveyancing and Property Law Handbook, 6th Edition
Butterworths Hong Kong Conveyancing and Property Law Handbook, 6th Edition

List Price: S$306.00

S$296.82 Save S$9.18 (3%)

A Practical Guide to Resolving Shareholder Disputes, 2nd Edition
A Practical Guide to Resolving Shareholder Disputes, 2nd Edition

List Price: S$306.00

S$296.82 Save S$9.18 (3%)

Tort Law in Hong Kong, 5th Edition (Hardcopy + ebook)
Tort Law in Hong Kong, 5th Edition (Hardcopy + ebook)

List Price: S$425.00

S$412.25 Save S$12.75 (3%)

Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book)
Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book)

List Price: S$543.66

S$527.35 Save S$16.31 (3%)

Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book)
Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book)

List Price: S$483.31

S$468.81 Save S$14.50 (3%)

Hong Kong Company Law, 15th Edition
Hong Kong Company Law, 15th Edition

List Price: S$83.64

S$81.13 Save S$2.51 (3%)

Private Equity in Hong Kong and China, 4th Edition
Private Equity in Hong Kong and China, 4th Edition

List Price: S$340.00

S$329.80 Save S$10.20 (3%)

Brooke's Notary Hong Kong, 3rd Edition
Brooke's Notary Hong Kong, 3rd Edition

List Price: S$289.00

S$280.33 Save S$8.67 (3%)

Butterworths Hong Kong Employees' Compensation Handbook, 7th Edition
Butterworths Hong Kong Employees' Compensation Handbook, 7th Edition

List Price: S$357.00

S$346.29 Save S$10.71 (3%)