Relevant bibliographies by topics / Advance Tax Rulings

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Academic literature on the topic 'Advance Tax Rulings'

Author: Grafiati
Published: 4 June 2021
Last updated: 25 April 2022

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Journal articles on the topic "Advance Tax Rulings"

1

Bartes, Richard. "Legal Institute of Advance Tax Rulings." Białostockie Studia Prawnicze 24, no. 3 (2019): 157–64. http://dx.doi.org/10.15290/bsp.2019.24.03.12.

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2

Kawatra, Gagan Kumar. "Advance income tax rulings - developments across the globe." Intertax 20, Issue 8/9 (August 1, 1992): 508–14. http://dx.doi.org/10.54648/taxi1992070.

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3

Huesecken, Birgit, and Michael Overesch. "Tax Avoidance through Advance Tax Rulings – Evidence from the LuxLeaks Firms." FinanzArchiv 75, no. 4 (2019): 380. http://dx.doi.org/10.1628/fa-2019-0011.

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4

Arena, Amedeo. "State Aids and Tax rulings: an assessment of the Commission’s recent decisional practice." Market and Competition Law Review 1, no. 1 (September 5, 2019): 49–79. http://dx.doi.org/10.7559/mclawreview.2017.308.

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Tax rulings are binging decisions that taxpayers may seek from tax authorities to determine in advance how certain transactions will be treated fiscally. However, tax rulings can have an “alternative use”: that of granting a particularly advantageous fiscal treatment to specific taxpayers, typically large multinational groups willing to invest and create jobs in the tax jurisdiction concerned, without extending it to other taxpayers and without triggering a tax war with other jurisdictions. This article focuses on the European Commission’s enforcement of State aids rules against certain EU Member States in respect of tax rulings issue to a number of multinational companies. After a brief account of the economic rationale for tax rulings and their potential relevance in the context of EU tax competition, the article provides an overview of the Commission’s individual and general measures designed to attract multinational investors in return for significant fiscal advantages. The central part of the article provides an analytical assessment of the Commission’s on-going and closed proceedings on tax ruling practices, having regard to the four constituent elements of the notion of State aid. Regard is then had to the peculiar challenges involved with recovery of State aids granted in the form of tax rulings and, finally, to the systemic implications of the Commission’s initiatives for the division of competences between the EU and its Member States and for the establishment of a fiscal union.
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5

Brodzka, Alicja. "Better governance through more transparency on advance cross-border tax rulings." Journal of Governance and Regulation 6, no. 1 (2017): 7–11. http://dx.doi.org/10.22495/jgr_v6_i1_p1.

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In recent years, the challenge posed by tax fraud and tax evasion has increased considerably and has become a major concern within the European Union. As a consequence, in the European initiatives a special emphasis has been laid on the actions aimed at reinforcing the anti-abuse provisions in bilateral tax treaties, national legislation and EU corporate legislation. Any artificial arrangement carried out for tax avoidance purposes would be ignored and companies would be taxed instead on the basis of actual economic substance. The aim of the article is presenting the European initiative aimed at implementing the automatic mode of the exchange of information on cross-border tax rulings and advance pricing arrangements. The paper investigates if the implemented measure can help Member States to detect certain abusive tax practices taken by companies, and to take the effective actions in response. It also tries to answer the question whether the initiative can result in more transparency and – as a consequence – in much better governance, both at the states’ and the corporations’ level.
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6

Sawyer, Adrian. "Professor John Prebble's Guiding Hand in New Zealand's Advance (Binding) Rulings Regime." Victoria University of Wellington Law Review 52, no. 4 (January 26, 2022): 939–62. http://dx.doi.org/10.26686/vuwlr.v52i4.7426.

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At first glance, one could be excused for concluding that New Zealand's advance (binding) rulings regime can be traced to a Government budget announcement in 1992. In reality, the early efforts of Professor John Prebble in the mid-1980s laid the groundwork that eventually resulted in a binding rulings regime commencing in 1995. John's contributions not only provided input from reviewing comparative jurisdictions, but also a draft code. Furthermore, post-regime, John was instrumental in endorsing the regime through his membership of the Committee of Experts on Tax Compliance (the Committee). Beyond this, further refinements to the regime (including more cost-efficient and accessible short process rulings) to a large degree reflect John's early observations. That is, businesses need certainty when making decisions that affect their tax obligations imposed by complex legislation and they should have access to a facility that can enhance that certainty.
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7

Diller, Markus, Pia Kortebusch, Georg Schneider, and Caren Sureth-Sloane. "Boon or Bane? Advance Tax Rulings as a Measure to Mitigate Tax Uncertainty and Foster Investment." European Accounting Review 26, no. 3 (May 24, 2016): 441–68. http://dx.doi.org/10.1080/09638180.2016.1169939.

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8

Rossi-Maccanico, Pierpaolo. "Fiscal State Aids, Tax Base Erosion and Profit Shifting." EC Tax Review 24, Issue 2 (April 1, 2015): 63–77. http://dx.doi.org/10.54648/ecta2015008.

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In this article, the author describes the application of State aid rules in reviewing EU Member States' tax measures for multinationals providing possibilities for tax arbitrage (Base erosion and profit shifting - BEPS). The author provides examples of measures favouring tax arbitrage which are identifiable as State aid if analysed from that perspective and explains how the application of State aid rules is theoretically justifiable and even more appropriate from an EU perspective rather than the use national anti-abuse rules. The author suggests that State aid review is a more effective instrument to tackle abusive tax planning in the EU, because a supranational regulator, subject to EU judicature control, manages it. The author considers that the power of the tax administrations to correct the taxpayers' determinations of their taxable income and fix them on the basis of independent criteria is intrinsically discretional and that transfer-pricing corrections may be cast into legal uncertainty. Accordingly, a new procedural framework is required to restore legal certainty to an area of State aid control which puts into question the proper implementation of the transfer-pricing power of correction by the competent tax administrations. With the grant of an advance ruling a tax administration provides advance certainty about the acceptable determination of the taxable income that a taxpayer should follow; which the author considers to be a sui-generis special right within the meaning of Article 106(1) TFEU. The article accordingly suggests that the Commission adopts a directive under Article 106(3) TFEU to define the conditions under which individual rulings can be granted in respect of undertakings enjoying special rights such as the multinationals being the recipients of transfer-pricing adjustments.
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9

Larsson, Jesper, and Eva-Lotta Päiviö Sjaunja. "Hunting by Early Modern Lule Sami Households." ARCTIC 74, no. 3 (October 5, 2021): 323–38. http://dx.doi.org/10.14430/arctic73281.

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Hunting was one of three pillars, along with fishing and reindeer husbandry in the early modern Sami economy, and understanding of Sami hunting has increased during recent decades. However, most research has concentrated on time periods before AD 1600. After AD 1600 and the initial formation of modern Nordic countries, hunting ceased to be the backbone of the overall Sami economy but continued as an integral part of household economies. Our aim is to advance understanding of early modern hunting in northwestern interior Fennoscandia. Using source materials including court rulings and historical accounts, we set out from a self-governance perspective focusing on how actors solved resource distribution with regards to hunting. We show that ecological differences between mountains and forest impacted decisions about hunting. From the 1500s to the end of the 1700s, hunting led to the extinction of wild reindeer and depopulation of fur animals, while small-game hunting for subsistence continued to be important. In the forest region, strong property rights to game developed when skatteland (tax land) was established and hunting became a private enterprise. We suggest that the institution of skatteland was a response to changes in Sami economy, and the transition from collective to individual hunting was a contributing factor.
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10

Waerzeggers, Christophe, and Cory Hillier. "Introducing an Advance Tax Ruling (ATR) Regime." Tax Law Technical Note 1, no. 1 (2016): 1. http://dx.doi.org/10.5089/9781513511610.008.

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Dissertations / Theses on the topic "Advance Tax Rulings"

1

Romano, Carlo. "Advance tax rulings and principles of law : towards a european tax rulings system? /." Amsterdam : IBFD, 2002. http://www.gbv.de/dms/spk/sbb/recht/toc/35816916X.pdf.

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2

Romano, Carlo Alberto. "Advance tax rulings and principles of law : towards a European tax rulings system? /." Amsterdam : IBFD, 2002. http://bibpurl.oclc.org/web/31193.

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3

Kortebusch, Pia [Verfasser]. "Zur Attraktivität von Advance Tax Rulings (ATRs) und Advance Pricing Agreements (APAs) für Investoren und Steuerbehörden : The attractiveness of Advance Tax Rulings (ATRs) and Advance Pricing Agreements (APAs) for investors and tax authorities / Pia Kortebusch." Paderborn : Universitätsbibliothek, 2014. http://d-nb.info/1058913492/34.

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4

Diller, Markus, Pia Kortebusch, Georg Thomas Schneider, and Caren Sureth. "Boon or Bane? Advance Tax Rulings as a Measure to Mitigate Tax Uncertainty and Foster Investment." WU Vienna University of Economics and Business, Universität Wien, 2014. http://dx.doi.org/10.2139/ssrn.2442749.

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Politicians and tax practitioners often claim that tax uncertainty negatively affects investment. In many countries, firms can request fee-based Advance Tax Rulings (ATRs) to mitigate tax uncertainty. We analyze theoretically the circumstances under which investors request ATRs, how tax authorities should price them and how they can affect investment. We assume that tax authorities integrate investors' reasoning into their decisions. We find that it is often optimal for tax authorities to charge prohibitively high fees to discourage firms from requesting an ATR. However, we find that revenue-maximizing tax authorities offer ATRs if the ruling enables them either to significantly reduce their tax audit costs or to increase the probability of detecting ambiguous tax issues. Under certain circumstances, ATRs may effectively foster investment and potentially benefit both the tax authorities and taxpayers. Our results provide new explanations for why taxpayers that face high levels of tax uncertainty often do not request ATRs, even when the fee is rather low. Our results also hold when the tax authority maximizes social wealth instead of its revenues. Regulatory changes in ATR requirements might serve as a natural quasi-experiment for an empirical study of our predictions regarding investment decisions. (authors' abstract)
Series: WU International Taxation Research Paper Series
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5

Pettersson, Markus. "The Compatibility of Swedish CFC-legislation with article 43 EC : A case study of an Advance Ruling." Thesis, Jönköping University, JIBS, Commercial Law, 2006. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-1050.

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Most states within the EU have some kind of CFC-legislation that allows the state in question to tax its residents for gains accrued within foreign companies that they control. CFC-legislations are usually said to counteract tax avoidance and they generally target only income of companies in low tax regimes. Such tax regimes are however not only found in pure tax havens. Some of the member states of the EU have set up preferential tax regimes, often limited to foreign financial offshore activities. Can it be a restriction of the freedom of establishment in article 43 EC to tax a resident taxpayer on CFC-basis for the income of a company resident in another member state? In the affirmative, can such a restriction be justified and if so, on which ground? Can it perhaps be easier to argue in favour of CFC-rules after the recent judgment of Marks and Spencer where the ECJ seems to have applied a broader ground of justification in respect of the counteraction of tax avoidance?

These are some of the main questions dealt with in this thesis.

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6

Lo, Wen-Ting, and 羅文廷. "Taxpayers'' Rights Protection－The Study On Advance Tax Rulings System." Thesis, 2013. http://ndltd.ncl.edu.tw/handle/19468014321134224112.

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碩士
國立臺灣大學
法律學研究所
101
Abstract Paying tax in accordance with law is one of the important obligations of people. In the past, competent financial authorities put their emphasis of tax legislature more on the achievement of the target financial income and the efficiency of the tax administrations to accomplish the purpose of taxation. However, from the 80s, as the rise of the ideas of autonomy and the evolution of the character the country plays, protection for the taxpayers’ rights become the main point for tax reformation and gain more universal attention. Many countries have adopted advance tax rulings system to fulfill the right to certainty of the Taxpayers’ Rights Advocate. Taxpayers can apply for a tax ruling to tax administration in advance to know the influence of certain transaction will do on their tax payments. Through tax ruling, tax payers can have more chances to organize their financial plans, decrease tax risk and lower the possibility of disputation between tax payers and the tax administration. Ministry of Finance of Taiwan announced Working Guidelines for Advance tax rulings on December 30th, 2003 to implement advance tax rulings system. The category of case, review division, review procedures and other items are all regulated and listed in the guideline. However, there weren’t many applications for the ruling. Advance tax rulings system is considered as a system that protects taxpayers’ rights. This thesis will first explains the important principles such as human dignity, rule of law, rule of democratic state and studies how to protect taxpayers’ rights by adopting advance tax rulings system. Then introduces the advance tax rulings systems of U.S.A., Korea, Hong Kong then explains the developed reason and articles in the guideline of Taiwan’s advance tax rulings system. By inspecting form the view point of Taxpayers’ Rights Advocate and by comparing the cases of other countries, this thesis also analyze Taiwan’s tax payment system to find out the deficiency of our system and the reason why taxpayers did not like to use it. Finally, this thesis proposes a few suggestions for the amendment of the tax legislatures in the hope of achieving the goal of Taiwan’s advance tax rulings system to protect our taxpayers.
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7

Leal, Vivian de Castro Morales. "A concretização progressiva da lei nos limites (e por exigência) da legalidade fiscal : o caso dos APA's e dos ATR's holandeses." Master's thesis, 2014. http://hdl.handle.net/10316/28454.

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8

Lin, Chih-Yang, and 林志揚. "The study on R.O.C''s advance tax ruling system." Thesis, 2004. http://ndltd.ncl.edu.tw/handle/37971115260809167306.

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Abstract:
碩士
國立臺灣大學
會計與管理決策組
92
Following the trend of globalization, the international trade and economic activities grow rapidly and vigorously. Under the tidal waves of internationalization, Taiwan needs to reform its tax environment so as to maintain the economic superiority in Asia and Pacific region. Especially, after joining WTO the economic and trade contact between Taiwan and other countries became more frequent ever than before, though a sound and complete tax levying system is still not yet established in Taiwan for governing the across-countries investment activities. Foreign investors expected more transparent taxes and levies system to be established in Taiwan, and suggested Taiwan to establish the Advance Tax Rulings system by imitating the system of those developed countries in America and Europe for handling the tax levying of the specific transaction so that the unpredictable risk of tax burden can be reduced, and the unnecessary controversy between taxpayer and government can be minimized. After careful evaluation, the Ministry of Finance adopted the suggestions of those foreign investors, and promulgated the regulation of “Working Guidelines for Advance Tax Rulings” that was a new milestone for the internationalization of tax environment of Taiwan. However, there is still considerable difference between the system adopted by Taiwan and the system of other countries in the world. It seems that there is still the considerable space for making further improvement. The purpose of the paper is to discuss the difference and similarity between the Advance Tax Rulings System in Taiwan and that of the other countries. Meanwhile, suggestions on the amendment of the relevant laws are proposed in the paper, including the discussion of the feasibility of changing the current system which treats advance rulings as administrative rulings to a new system which treats advance rulings as “Administration Order” or “Administration Contract.” In addition, other suggestions such as changing the system to Fee-collecting system, extending the range of service, inviting experts and scholars in the relevant fields to join the committee as committee members are also proposed.
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9

Tai, Yi-San, and 戴衣姍. "Advance Tax Ruling System As Due Process Of Law Of Tax In Republic Of China." Thesis, 2016. http://ndltd.ncl.edu.tw/handle/24325657363772759366.

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碩士
國立臺灣大學
科際整合法律學研究所
104
Advance tax ruling system was designed in 2003. In that time, ROC endeavored to join WTO, so this system was regarded as a special tax service for foreign investment. Dissimilar to other else countries’ advance tax ruling system, in order to maintain stability of law, ours ruling result has no law power. So that, it isn’t effective until now. This thesis will discuss Due Process of Law. In one way, it can defend infringement to human rights from nation’s power; in the other way, the objective function of fundamental rights lead to nation’s obligation, so administrative power should help people to enforce right to freedom of tax planning. In this perspective, current law and system must be modified a lot in both substantial and procedural law. This thesis think the system should be more open to accept more applications, and the ruling result may be made an administrative penalty. As for hearing in paper can’t protect rights enough, this paper propose that hearing in oral will be better.
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10

Maluleke, Mikateko Joyce. "A critical analysis of the doctrine of legitimate expectation in the context of the advance tax ruling system and tax assessment measured by SARS, with specific emphasis on substantive legitimate expectation." Diss., 2012. http://hdl.handle.net/2263/27892.

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Section 1 of the Income Tax Act, 58 of 1962 (the Income Tax Act) and other related Revenue Acts empower the South African Revenue Service (SARS) to administer the Acts and to collect revenue for the government of the Republic of South Africa. Sometimes, in order to assess tax liability and collect revenue, the Commissioner and/or officials of SARS have to make certain representations and undertakings to taxpayers in general through interpretation notes, rulings, and other forms of communication. In certain circumstances, SARS is authorised to withdraw rulings made and at times already acted upon, often to the taxpayer’s detriment. This results in lack of clarity, uncertainty and inconsistency in the application of the law. In order to address this problem, an Advanced Tax Ruling System (ATRS) was introduced. In terms of the ATRS, the issuing of rulings is statutorily regulated and binding on both the taxpayer and SARS when certain conditions provided for in the Income Tax Act are met. The purpose of an ATRS is to promote clarity, consistency, and certainty in respect of the interpretation or application of the provisions of tax laws to which it applies. However, the Commissioner is not obliged to follow a policy or undertaking which is in violation of tax laws. Section 76N(3) provides that the Commissioner may withdraw or modify a binding private ruling, or a binding class ruling retrospectively, if the ruling was made in error; subject to sub paragraphs (a), (b) and (c) thereof. This creates uncertainty as opposed to the intention for which the ATRS was introduced. The critical question is, if the Commissioner timeously informed the taxpayer that he has decided not to honour the undertaking made in a valid binding private ruling, which is still in force to the detriment of the taxpayer, can the taxpayer raise a defence of substantive legitimate expectation? It is argued that the issuing of an ATR is an administrative action subject to judicial review, if, in the opinion of the concerned party, it will have an adverse effect. Further, in the event that the Commissioner informs the taxpayer timeously of the intention to withdraw a valid binding private ruling, which the taxpayer has acted upon to their detriment, can they raise a defence of a practice generally prevailing and/or substantive legitimate expectation? The doctrine of legitimate expectation as a defence was authoritatively accepted as part of the South African administrative law in the landmark case of Administrator Transvaal v Traub. However, Chief Justice Corbett expressly stated in a dictum that the content of the expectation may be substantive or procedural in nature, [but] the protection of that expectation, if found to be legitimate, was exclusively procedural. It is argued that the dictum ignores section 33 of the Constitution which introduced reasonableness as an element of the right to just administrative action, which means that the substance of a decision may be reviewed if it is unreasonable. The objective is to examine whether the courts could develop the doctrine of legitimate expectation beyond the procedural protection, as already done in countries in Europe. Copyright
Dissertation (LLM)--University of Pretoria, 2012.
Mercantile Law
unrestricted
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Books on the topic "Advance Tax Rulings"

1

Romano, Carlo Alberto. Advance tax rulings and principles of law: Towards a European tax rulings system? Amsterdam: IBFD, 2002.

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2

Rijkele, Betten, and International Bureau of Fiscal Documentation., eds. The new Netherlands transfer pricing regime: Amended advance pricing agreements and advance tax rulings procedures. Amsterdam: IBFD Publications, 2002.

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Book chapters on the topic "Advance Tax Rulings"

1

Kovacevic, Natasa Zunic. "Coordinating Taxation Between the European Union and Other Countries Through Advance Tax-Rulings Systems." In Financial and Monetary Policy Studies, 87–94. Berlin, Heidelberg: Springer Berlin Heidelberg, 2013. http://dx.doi.org/10.1007/978-3-642-35697-1_5.

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Conference papers on the topic "Advance Tax Rulings"

1

Szabó, Ildikó. "Advance Tax Ruling." In MultiScience - XXX. microCAD International Multidisciplinary Scientific Conference. University of Miskolc, 2016. http://dx.doi.org/10.26649/musci.2016.122.

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2

Çelik, Sabahat Binnur. "The Limits of State Intervention in Economy by Taxation in Turkey." In International Conference on Eurasian Economies. Eurasian Economists Association, 2015. http://dx.doi.org/10.36880/c06.01314.

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People, mostly and directly affected from the state's decision about taxation. State, in order to realize public services, while using its taxation authority depending to its power of sovereignty, intervenes in the economy in different ways. While using taxation authority, state is subject to various limitations. The most important limitation about taxation is the necessity of obeying the laws. The basic principles about taxation are indicated on the Universal Declaration of Human Rights and Constitutions. Nowadays, nearly in every country, advanced tax payer rights, public pressure and the ruling parties’ intent about remaining in power or the opposition parties' intent about coming in power also determines the limits of taxation. Proceedings of the independent judicial bodies are very important about the limitation of taxation. Because independent judicial bodies can control the power of sovereignty of the state about taxation. In the judging process, they judge the tax rules and tax applications' harmony to the basic principles of taxation. If there are no fair limits about taxation in a country, this means that there is no democracy in that country.
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