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The Art and Craft of Judgment-Writing: A Primer for Common Law Judges

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Case Notes 4th ed




 P. M. Callow


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Judicial Cooperation in Commercial Litigation 3rd ed (The British Cross-Border Financial Centre World)



 Ian Kawaley, David Doyle, Shade Subair Williams


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A Practitioner's Guide to International Tax Information Exchange Regimes: DAC6, TIEAs, MDR, CRS, and FATCA


ISBN13: 9781913507237
Published: September 2021
Publisher: Spiramus Press Ltd
Country of Publication: UK
Format: Paperback
Price: £99.95



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The recent introduction of the Directive on Administrative Cooperation in the field of taxation 6 (DAC6) and mandatory disclosure regimes by many jurisdictions have led to a large number of professionals potentially being required to disclose information in relation to their clients’ arrangements.

The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years including the OECD common reporting standards DAC6 and MDR. They set them in their historical context as well as giving a technical analysis of the regimes. They focus on the guidance offered by the Irish and UK tax authorities with reference to other guidance in Europe and beyond, where appropriate.

Subjects:
Taxation
Contents:
Guidance Abbreviations
Introduction
1. History and Contexte Regime (MDR)
2. Types of Exchange
3. Interpretation
4. Disclosure of Tax Avoidance Schemes (‘DOTAS’)
5. Foreign Account Tax Compliance Act - FATCA
6. CRS
7. The Directive on Administrative Cooperation 6 (‘DAC6’) and the Mandatory Disclosure Regime (‘MDR’)
8. DAC6 Definitions
9. The Hallmarks and Reporting
10. MDR
11. TIEAs and Exchange Under Double Tax Treaties
Index