Group taxation (special schemes according to whic... more

Group taxation (special schemes according to which a group of companies meeting certain requirements may be assimilated for tax purposes to a single company) exists in several European Member States and is now under consideration in an EU proposal concerning a common consolidated corporate tax base (CCCTB). Its rationale as a potential EU tax regime has arisen from a series of high-profile ECJ cases concerning cross-border tax relief claims--decisions which have been criticized for lack of clarity and for breach of freedom of establishment (Article 49 TFEU). Group taxation has now become one of the most intensively debated issues in EU tax law. The papers collected in this timely book derive from an ACTL Seminar held at Amsterdam in April 2010. The thirteen authors are either well-known practitioners from major law firms and accounting firms, or noted European tax scholars, or both. Among the central issues covered in the book are the following: *the underlying tax obstacles which exist for companies operating in more than one Member State *potential for tax avoidance *prevention of double use of losses (the "no possibilities" test) *disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty *the concept of "balanced allocation of taxing powers" *meaning of "final losses" *the "Bosal fix" *cash-flow disadvantages of having to carry losses forward *deduction of currency losses *deduction-and-recapture rules and VAT grouping.... less

Virtually all international taxation provisions u... more

Virtually all international taxation provisions ultimately stem from two fundamental sources, both originating at the OECD: The Model Tax Convention (on which more than 3,000 bilateral tax treaties are based), and the Transfer Pricing Guidelines. During 2010, major revisions were made to both. This is the first publication to describe and analyse these amendments in depth. From a variety of perspectives, thirteen experts lawyers, tax directors, representatives of the OECD and of tax administrations, and academics discuss the updates and the issues that may arise regarding their interpretation and application. The significant changes covered include: *application of tax treaties to collective investment vehicles; *application of tax treaties to state-owned entities, including sovereign wealth funds; *issues regarding short-term cross-border employment income; *application of tax treaties to international telecommunication operations; *selection of the most appropriate transfer pricing method to the circumstances of the case; *the transfer pricing aspects of business restructurings; *how to apply transactional profit methods; and *how to perform a comparability analysis. This unique book provides an expert analysis of current, important topics in international taxation and transfer pricing. As such, it is a welcome and valuable resource for tax lawyers and consultants, corporate tax advisers, government officials and others involved in the international tax law market, as well as for academics and researchers in the field.... less

Toyota rose from the ashes of World War II to bec... more

Toyota rose from the ashes of World War II to become, just fifty years later, one of the dominant automakers in the world. How did Toyota do it? How did it go from making cars that Westerners pointed to and laughed at to making cars, like the Lexus, that people now lust after? Thats what this book is all about. As veteran writer K. Dennis Chambers shows, Toyota, crazy like a fox, had a long-term plan to become a top-tier player in the auto industry. Through patience, persistence, and a willingness to dream of a different future as well as to look back to the past for ideas, Toyota has succeeded step by step.Toyota has never been afraid to chart its own path. Readers will learn what makes Toyota tick through Chamberss penetrating text, which: Explains the importance of the company and the essential disruptions that changed business forever. (Think Prius.) Details Toyotas origins and history. Presents biographies of the founders and the historical context in which they launched the company. Explains Toyotas strategies and innovations.In addition, Chambers offers special features that include a look at the colorful people associated with Toyota, interesting trivia, a Toyota time line, a focus on products, a look at how the company treats and trains its workers, and where the company is headed. Toyota a company that changed, and is changing, the world.... less