Everywhere, new tax rules are under development to engage with the ever-increasing complexity and sophistication of aggressive tax planning and to reverse the tax base erosion it leads to. The most prominent initiative in this context is the Base Erosion and Profit Shifting (BEPS) project of the OECD. Although double non-taxation is among the main issues the BEPS project intends to address, this book shows that this phenomenon has not yet been fully understood. Focusing on the fundamental freedoms and the State aid rules of the EU, this book thoroughly explains the nature of double non-taxation from an EU law perspective, its relation to double taxation, and the impact of EU law on these phenomena.
Among the issues dealt with in the course of the analysis are the following:
The tax jurisprudence of the ECJ is referred to and comprehensively analysed throughout this whole book. A final chapter provides an outlook on possible developments in the future.
By providing the first in-depth analysis of EU law's impact on double non-taxation - and the double taxation relief standards with which it is intimately related - this book takes a giant step towards greater legal certainty in this challenging area of tax law. It will quickly take its place as a major practical analysis which benefits tax authorities, scholars, and tax practitioners across Europe and even beyond.
. . the book is enlightening for practitioners who are often required to take into account global considerations when advising clients.
A Neofederalist Vision of TRIPS by Graeme B. Dinwoodie and Rochelle C. Dreyfuss examines its interpretation, its impact on the creative environment, and its effect on national and international lawmaking.
Carsten Fink is presently Chief Economist at WIPO. TIGHTENING TRIPS: THE INTELLECTUAL PROPERTY PROVISIONS OF RECENT U.S. FREE TRADE AGREEMENTS Carsten Fink & Patrick Reichenmiller” INTRODUCTION Over the past few years, the United States ...
This is a general reference work on all aspects of intellectual property, including international treaties and conventions, analyses of all fields of intellectual property, its administration, enforcement and teaching, technological and ...
See also, Nuno Pires de Carvalho, The TRIPS Regime of Trademarks and Designs, 2nd Edn., (Kluwer Law International, 2011) paras 15.34, 15.40. This approach to the interpretation of the third sentence of Article 15.1 was also adopted by ...
Compiled by the China National Intellectual Property Administration (CNIPA) with the support of the WIPO China Funds-in-Trust, this book gives students a basic yet comprehensive understanding of IP. Using a question-and-answer format, it ...
This thought-provoking volume offers an update on current international IPR negotiations and includes case studies on software, computer chips, optoelectronics, and biotechnologyâ€"areas characterized by high development cost and easy ...
1: Introduction 2: International Harmonization of Tariff-related Rules 3: International Harmonization of Trade Remedy Rules 4: International Harmonization of Standards and Accreditation 5: International Harmonization of Intellectual ...
In order to place the 25 years in a historical context, the essay does, exceptionally, deal also with pre-1967 events and with post-1992 possibilities.
Technology and Innovation Support Centers (TISCs) are designed to provide innovators in developing countries with access to locally based, high quality technology information services and other related services.