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Tax Sovereignty in the BEPS Era


ISBN13: 9789041167071
Published: June 2017
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £144.00



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Tax Sovereignty in the BEPS Era focuses on how national tax sovereignty has been impacted by recent developments in international taxation, notably following the OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project.

The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with or even impedes that of another.

In this collection of chapters, internationally respected practitioners and academics reveal how the OECD’s BEPS initiative, although a major step in the right direction, is insufficient in resolving the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post-BEPS world.

What’s in this book:-

Following a country-by-country reporting structure, the contributors provide an in-depth analysis of such relevant issues as the following:-

  • why multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy;
  • how digital commerce has upended traditional notions of source and residence;
  • why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system;
  • how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and
  • transfer pricing reform.
How this will help you:-

This book helps readers navigate in these uncertain BEPS times, as well as provides insightful assessments on how countries’ tax policies might change in the near future. Through these chapters the authors provide authoritative commentaries on the necessary preconditions for exercising the power to tax in today’s world and the impacts of the emergence of the digital economy.

Their perspectives and recommendations prove to be highly essential to all policymakers, legislators, practitioners, and academics in the international taxation arena regarding information that is essential for interpretation and decision-making in the current international tax environment.

Subjects:
Taxation
Contents:
Editors
Contributors
Preface

Part I The Essential Paradox of Tax Sovereignty
Chapter 1 BEPS and the Power to Tax
Allison Christians            
Chapter 2 Tax Sovereignty and Digital Economy in Post-BEPS Times
Ramon Tomazela Santos & Sergio André Rocha
CHAPTER 3 Justification and Implementation of the International Allocation of Taxing Rights: Can We Take One Thing at a Time?
Luís Eduardo Schoueri & Ricardo André Galendi Júnior
Chapter 4 An Essay on BEPS, Sovereignty, and Taxation

Part II    Challenge to the Foundational Principles of Source and Residence
Chapter 5 Evaluating BEPS
Reuven S. Avi-Yonah & Haiyan Xu
Chapter 6 Jurisdictional Excesses in BEPS’ Times: National Appropriation of an Enhanced Global Tax Basis
Guillermo O. Teijeiro
Chapter 7 Taxing the Consumption of Digital Goods
Aleksandra Bal

Part III  Acceptance and Implementation of Consensus by Differently-Situated States
Chapter 8 The Birth of a New International Tax Framework and the Role of Developing Countries
Natalia Quiñones
Chapter 9 The Other Side of BEPS: “Imperial Taxation” and “International Tax Imperialism”
Sergio André Rocha
Chapter 10 Country-by-Country Over-Reporting? National Sovereignty, International Tax Transparency, and the Inclusive Framework on BEPS
Romero J.S. Tavares
Chapter 11 How Are We Doing with BEPS Recommendations in the EU?          
Tomas Balco & Xeniya Yeroshenko        
Chapter 12 U.S. Tax Sovereignty and the BEPS Project
Tracy A. Kaye

Index

Series: International Taxation

The International Tax Law Concept of Dividend 2nd ed (eBook) ISBN 9789041183958
Published June 2017
Kluwer Law International
£154.00
(ePub)
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The International Tax Law Concept of Dividend 2nd ed ISBN 9789041183941
Published June 2017
Kluwer Law International
£154.00
Taxation and Migration (eBook) ISBN 9789041161444
Published October 2015
Kluwer Law International
£159.00
(ePub)
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Taxation and Migration ISBN 9789041161369
Published October 2015
Kluwer Law International
£159.00
Taxation of Derivatives ISBN 9789041159779
Published August 2015
Kluwer Law International
£237.00
The VAT/GST Treatment of Public Bodies ISBN 9789041146632
Published January 2013
Kluwer Law International
£167.00
Science, Technology and Taxation ISBN 9789041131256
Published July 2012
Kluwer Law International
£167.00
£167.00
Immovable Property under VAT: A Comparative Global Analysis ISBN 9789041131263
Published May 2011
Kluwer Law International
£167.00
Transfer Pricing and the Arm's Length Principle in International Tax Law ISBN 9789041132703
Published September 2010
Kluwer Law International
£204.00
Systems of General Sales Taxation: Theory, Policy and Practice ISBN 9789041128324
Published August 2009
Kluwer Law International
£185.00
Taxpayers Rights: Theory, Origin and Implementation ISBN 9789041126504
Published September 2007
Kluwer Law International
£250.00
Tax Treaty Law and EC Law ISBN 9789041126290
Published August 2007
Kluwer Law International
£182.00
Tax Investment Incentives in Foreign Direct Investment ISBN 9789041122285
Published April 2004
Kluwer Law International
£196.00
Out of print
International and Comparative Taxation: Essays in Honour of Klaus Vogel ISBN 9789041198419
Published September 2002
Kluwer Law International
£154.00
£243.00