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Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policymakers, with a far-reaching impact on countries'legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments, along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers seven topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, it encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing and Amount B; Transfer Pricing and BEFIT; The EC's Transfer Pricing Directive Proposal; Transfer Pricing and Profit Attribution to New-Age Permanent Establishments; Transfer Pricing and ESG; and Transfer Pricing and New Technologies. The intense work of international organizations, such as the OECD, the UN, and the EU, is thoroughly analysed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, government officials and tax lawyers, in-house counsel, and interested academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

This book is a commonsense guide to becoming a reflective practitioner, written by a practitioner for practitioners. This second edition is fully revised and updated, incorporating extensive new material emphasizing hands-on tools, worksheets, and guides along with practical advice for those interested in adopting reflective practice individually or in a group setting. It also provides useful resources, step-by-step instructions, and more case studies and commentaries from practitioners.Every person in a conflict resolution process sees the world differently and acts in a distinctive manner. Yet, by following well-developed practice routines, practitioners often fail to consider the unpredictability of human interactions and overlook behaviors that are inconsistent with their expectations. To respond effectively to surprising and unpredictable events, this book encourages practitioners to adapt their thinking, so they can use their knowledge and skills when situations do not match their assumptions or are inconsistent with their practice routines. This book also includes guest essays by Ava Abramowitz, Jodie Grant, Tzofnat Peleg-Baker, and Susanne Terry.

CJEU - The most important cases in the field of direct taxation A great number of cases pending before the European Court of Justice (CJEU) concern the fundamental freedoms and state aid in respect of direct taxation. In particular, the number of infringement procedures brought before the CJEU by the European Commission has been increasing year on year. The CJEU is a driving force in the field of direct tax harmonization. All judgments and pending cases, therefore, have to be carefully analysed by academics as well as practitioners. This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and State aid rules are analysed. The analyses are presented by esteemed national and European tax law experts. The contributing authors´ focus on the preliminary questions submitted to the CJEU by the national courts and the CJEU case law could be of relevance for driving future judgments. This book goes to the heart of the national tax systems, exposing hidden obstacles to the fundamental freedoms.

The most important and recent judgments of the CJEU Considering the ever-increasing importance of indirect taxation as a source of revenue for governments, the intensifying complexity of the legal framework, and the proliferating number of countries adopting indirect taxation, it is essential to scrutinize how the law is applied in practice. The primary driving force in this area is, undoubtedly, the Court of Justice of the European Union. This book analyses selected topics (e.g., fighting VAT fraud, obligations imposed on digital platforms, taxable person, taxable transactions, place of supply, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the Court of Justice of the European Union. Experts from all over the world, not just from academia but also government and judiciary representatives, as well as tax practitioners, have provided their input and helped us compile what is an informative and worthy read for anyone dealing with indirect taxation on a professional basis.

- Kompakte Orientierungshilfe für CISOs, Sicherheitsverantwortliche in Unternehmen, Projektleitende, IT-Berater:innen - Best Practices für die Umsetzung im Unternehmen- Mit Erfahrungsberichten mehrerer Chief Information Security Officer (CISO)- Ihr exklusiver Vorteil: E-Book inside beim Kauf des gedruckten BuchesFür Unternehmen ist es existenziell, die Sicherheit ihrer Informationen, Systeme und Produkte zu gewährleisten. Dies trifft heute mehr denn je zu, denn mit zunehmender Vernetzung wächst auch die Angriffsfläche: Jedes vernetzte Gerät ist ein potenzielles Einfallstor für Gefährdungen, und das erhöht das Risiko zusätzlich. Doch wie können Sie Ihr Unternehmen vor diesen Gefährdungen schützen und Sicherheit gewährleisten?Die Antwort auf diese Frage – und viele hilfreiche Impulse und Best Practices – bietet Ihnen dieser Praxisratgeber zum Thema IT-Sicherheit. Es werden alle für Entscheider:innen relevanten Aspekte der IT-Sicherheit beschrieben und das für weiterführende Entscheidungen erforderliche Know-how zielgerichtet vermittelt. Das Buch dient als Leitfaden auf Ihrem Weg zur konsequenten und gleichzeitig effizienten Sicherstellung und Umsetzung von IT-Sicherheit im Unternehmen.Aus dem Inhalt- Ziele von IT Security (Vertraulichkeit, Integrität, Verfügbarkeit)- Grundlegende Maßnahmen (Berechtigungen zuteilen, Ausfallplanung, Tests etc.)- Absicherung der IT-Infrastruktur im Unternehmen- IT Security in der Cloud- Systematische Umsetzung von Bedrohungs- und Risikoanalysen- Sichere Produktentwicklung- Sicherheit in Produktionsnetzen und -anlagen- Rechtliche Rahmenbedingungen- Organisation des IT-Sicherheitsmanagements im Unternehmen- Sicherheitsstandards und -zertifizierungen- Relevante Wechselwirkungen zwischen Datenschutz und IT-SicherheitBei den Autor:innen des Buches handelt es sich um ausgewiesene Expert:innen aus dem Themenbereich IT-Sicherheit. Dazu zählen Berater:innen, Entscheidungsträger:innen und Professor:innen sowie Sicherheitsverantwortliche aus Unternehmen.

This volume is a collection of papers on emerging concepts, significant insights, and novel approaches to Information Systems Development (ISD). It delves into the latest trends in ISD and examines how organizational goals, structure, and the business environment--including regulations and societal trends--can impact the creation and implementation of information systems. The book draws on invited papers selected from the proceedings of the 31st International Conference on Information Systems Development hosted by Instituto Superior Técnico, Lisbon, Portugal, on August 30-September 1, 2023 (ISD2023).The general theme of ISD2023 was'Information Systems Development, Organizational Aspects, and Societal Trends'. This volume is specifically designed for researchers who are interested in exploring the methodological and operational perspectives of Information Systems Development, as well as the impact of organizational aspects and societal trends.The primary target audience for this volume is those who want to deepen their understanding of ISD from both theoretical and practical perspectives.

Lernen hört nie auf!Nach dem Erfolg des ersten „Praxis-Guide für Digital Leader“ berichten in diesem Werk weitere erfolgreiche Digital Leader von ihren Erfahrungen bei der digitalen Transformation. Welche Konzepte, Strategien, Vorgehensweisen waren erfolgreich? Welche eher weniger? Welche Probleme oder Hindernisse mussten gemeistert werden? Was bedeutet Nachhaltigkeit im Kontext der Digitalisierung? Oder welche Rahmenbedingungen sind nötig und was muss bei der Umsetzung unbedingt beachtet werden? Fragen rund um die digitale Transformation werden direkt aus der Praxis beantwortet. Unverzichtbar für alle, die selber die digitale Transformation eines Unternehmens erfolgreich begleiten wollen!- Die digitale Transformation erfolgreich meistern- Stets dranbleiben und wissen, worauf es ankommt- Direkt von erfahrenen Digital Leadern lernen- Chancen nutzen und Risiken handhaben- Mit Erfolgsfaktoren und konkreten PraxistippsBei den Autorinnen und Autoren dieses Buches handelt es sich um elf erfolgreiche Digital Leader mit vielfältigsten Digital-Erfahrungen – in den meisten Fällen als Chief Digital Officer (CDO), Chief Information Officer (CIO) bzw. Chief Technology Officer (CTO) – aus verschiedensten Branchen:- Julia Bangerth- Simone Bock- Tobias Fausch- Julia Freudenberg- Stefan Latuski- Thomas Mannmeusel- Nino Messaoud- Gerrit Pohl- Sandra Rauch- Fedor Ruhose- Rosanna Sibora

A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 29 most important tax treaty cases that were decided around the world in 2022. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2023 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.

Basic knowledge of European Tax Law This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. The eighth edition adds new updates on the most essential changes and new case law of the CJEU in the field of European direct taxation. Furthermore, due to its particular importance, the EU Global Minimum Tax Directive is now covered in a separate chapter.

This volume is a collection of papers on emerging concepts, significant insights, and novel approaches on information systems development (ISD). It examines and investigates up-and-coming trends in ISD in general, emphasizing benefits and risks of Artificial Intelligence in the development and operation of Information Systems. The book draws on invited papers selected from the proceedings of the 30th International Conference on Information Systems Development hosted by Babeș-Bolyai University, Cluj-Napoca, Romania, August 31 - September 2, 2022 (ISD2022). The theme of ISD2022 was “Artificial Intelligence for Information Systems Development and Operations”. The conference focused on the interplay between Information Systems and Artificial Intelligence, trying to emphasize novel, smarter automation approaches and the mitigation of risks related to AI adoption. Primary readership of the volume are researchers interested in methodological and operational perspectives related to ISD in general, and to AI adoption as a means of digital transformation in particular.

In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book's comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.

This is an open access title available under the terms of a CC BY-NC-ND 4.0 International licence. It is free to read at Oxford Academic and offered as a free PDF download from OUP and selected open access locations. This book introduces a systematic framework for understanding and investigating lexical variation, using a distributional semantics approach. Distributional semantics embodies the idea that the context in which a word occurs reveals the meaning of that word. In contemporary corpus linguistics, that idea takes shape in various types of quantitative analysis of the corpus contexts in which words appear. In this book, the authors explore how count-based token-level semantic vector spaces, as an advanced form of such a quantitative methodology, can be applied to the study of polysemy, lexical variation, and lectometry. What can distributional models reveal about meaning? How can they be used to analyse the semantic relationship between near-synonyms, and to identify strict synonymy? How can they contribute to the study of lexical variation as a sociolinguistic variable, and to the use of those variables to measure convergence or divergence between language varieties? To answer these questions, the book presents a comprehensive model of lexical and semantic variation, based on the combination of a semasiological, an onomasiological, and a lectal dimension. It explains the mechanism of distributional modelling, both informally and technically, and introduces workflows and corpus linguistic tools that implement a distributional perspective in lexical research. Combining a cognitive linguistic interest in meaning with a sociolinguistic interest in variation, the authors illustrate this distributional methodology using case studies of Dutch and Spanish lexical data that focus on the detection of polysemy, the interaction of semasiological and onomasiological change, and sociolinguistic issues of lexical standardization and pluricentricity. Throughout, they highlight both the advantages and disadvantages of a distributional methodology: on the one hand, it has great potential to be scaled up for lexical research; on the other, its outcome does not necessarily neatly correspond with what would traditionally be considered different senses.

Transfer pricing and business restructurings: issues and developments In the ever-evolving global landscape, the ability of businesses to swiftly adapt is crucial for maintaining relevance and competitiveness. This imperative holds true for multinationals, which frequently engage in strategic restructuring of their operations, assets, and resources to realign with the dynamic shifts in market conditions. This dynamic approach enhances operational efficiency, cuts costs, and optimizes financial performance. However, the intricacies of restructuring, especially in the context of transfer pricing, pose considerable challenges. Despite elaborate guidance from the OECD and UN, transfer pricing considerations in business restructuring remain complex. Determining appropriate transfer pricing methodologies, finding comparable transactions, and ensuring accurate documentation present hurdles for both multinationals and tax administrations. This publication discusses the most important issues and recent developments related to this theme. It attempts to cover various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, that took place in October 2022 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.

Durch den digitalen Wandel entstehen immer mehr Daten, die für die Geschäftstätigkeit genutzt werden können. Für Unternehmen ergeben sich damit enorme Chancen und Risiken zugleich. Somit ist es für den zukünftigen Erfolg von Unternehmen entscheidend, wie gut es ihnen gelingt, relevante Daten zu sammeln, diese systematisch auszuwerten, daraus wertvolle Erkenntnisse abzuleiten und diese für die Geschäftstätigkeit zu nutzen.Die zentrale Grundlage dafür ist, dass die Mitarbeitenden des Unternehmens die erforderlichen Kompetenzen für eine erfolgreiche Nutzung von Daten besitzen.Dieses praxisorientierte Handbuch vermittelt alle relevanten Aspekte dazu:- Daten modellieren- Daten sammeln, aufbereiten und speichern- Daten analysieren- Daten visualisieren und präsentieren- Datenqualität gewährleisten- Data Governance umsetzen- Big Data sinnvoll nutzen- Datenschutz und Datensicherheit gewährleistenBei den Autorinnen und Autoren dieses Buches handelt es sich um zehn ausgewiesene Expertinnen und Experten:- Beate Navarro Bullock- Robert Butscher- Andreas Gadatsch- Benedikt Haag- Oliver Hummel- Stefan Karg- Christiana Klingenberg- Oliver Schwarz- Kristin Weber- Roland Zimmermann

The most important and recent judgments of the CJEU Considering the ever-increasing importance of indirect taxation as a source of revenue for governments, the intensifying complexity of the legal framework, and the proliferating number of countries adopting indirect taxation, it is essential to scrutinize how the law is applied in practice. The primary driving force in this area is, undoubtedly, the Court of Justice of the European Union. This book analyses selected topics (e.g. taxpayer rights in EU VAT law, bad debt and insolvency in VAT law, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the Court of Justice of the European Union. Experts from all over the world, not just from academia but also government and judiciary representatives as well as tax practitioners, have provided their input and helped us compile what is an informative and worthy read for anyone dealing with indirect taxation on a professional basis.

Von erfolgreichen Profis lernenDie digitale Transformation eines Unternehmens ist kein Projekt mit einem definierten Anfang und einem definierten Ende, sondern sie verlangt ein ständiges Dranbleiben, eine ständige Bereitschaft zur Weiterentwicklung und zur Veränderung kombiniert mit einem Wissen, welche Chancen und Risiken die unterschiedlichen digitalen Möglichkeiten bieten, und vieles andere mehr. Eine Herausforderung für jeden, der die digitale Transformation eines Unternehmens starten oder weiterentwickeln will.- Die digitale Transformation erfolgreich meistern- Direkt von erfahrenen Digital Leadern lernen- Chancen nutzen und Risiken handhaben- Mit Erfolgsfaktoren und konkreten PraxistippsIn diesem Werk berichten Digital Leader, die allesamt selber erfolgreich die digitale Transformation eines Unternehmens begleitet haben bzw. diese noch begleiten, von ihren Erfahrungen, Strategien, Erfolgskonzepten, aber auch von Problemen, Hindernissen und Rückschlägen. Im Zentrum stehen Fragen wie beispielsweise welche Strategien, Methoden und Vorgehensweisen bei der Umsetzung hilfreich sind, welche Rahmenbedingungen im Unternehmen geschaffen werden müssen oder was bei der Umsetzung unbedingt zu beachten ist.Bei den Autorinnen und Autoren dieses Buches handelt es sich um 14 erfolgreiche Digital Leader mit vielfältigsten Digital-Erfahrungen – in den meisten Fällen als Chief Digital Officer (CDO), Chief Information Officer (CIO) bzw. Chief Technology Officer (CTO) – aus über zehn Branchen:- Christian Ammer- Catalin Barbulescu- Harald Greiner- Rainer Karcher- Melanie Kehr- Antje König- Andreas Meyer-Falcke- Michael Müller-Wünsch- Bernd Preuschoff- Jörg Reinold- Jürgen Renfer- Anke Sax- Susanne Steffen- Bettina Uhlich

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries'legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.

A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties,'Tax Treaty Case Law around the Globe 2021'is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.

Wie Sie jeden Change erfolgreich meistern!Nichts bleibt so beständig wie der Wandel. Das gilt heute mehr denn je. Unternehmen, die langfristig überleben wollen, müssen sich immer wieder an die sich ständig verändernden Rahmenbedingungen anpassen. Voraussetzung hierfür ist ein professionelles Veränderungs- bzw. Change Management, das auch dauerhaft im Unternehmen implementiert wird. Führungskräfte spielen hierbei die zentrale Rolle: Sie müssen u.a. eine klare Orientierung geben, immer wieder aktiv den Wandel vorantreiben, mit Widerständen umgehen, Kosten und Zeit im Blick behalten, aber auch Markt- oder technologische Entwicklungen berücksichtigen. Dieses Workbook zeigt, wie diese Herkulesaufgabe zu bewältigen ist und zwar ganz konkret und direkt in die Praxis umsetzbar. Führungskräfte, Change Manager, erhalten einen konkreten Umsetzungsleitfaden, erfahren, was zu beachten ist und wo die Schwierigkeiten lauern. Konkrete Handlungsanweisungen, Checklisten und Arbeitshilfen erleichtern dabei den Praxistransfer.- Leitfaden für Entscheider- Alles Relevante rund um Veränderungsprozesse- Hoher Praxisbezug und gleichzeitig fundiert- Mit Checklisten und Arbeitshilfen

This volume features a collection of papers on emerging concepts, significant insights, novel approaches and ideas in information systems development (ISD). It examines and investigates up-and-coming trends in ISD in general, emphasizing the continuous collaboration between developers and operators to optimize the software delivery time. The book gathers selected papers from the 29th International Conference on Information Systems Development held at Universitat Politècnica de València, Spain, September 8-10, 2021. The theme of ISD2021 was “Crossing Boundaries between Development and Operations (DevOps) in Information Systems.” The revised and extended papers focus on the influences among information systems, organizational structures, processes and people from its conception to its operation. They examine methodological issues and ways in which the IS designers, developers and operators are transforming organisations and society through information systems.

The most important and recent judgments of the CJEU Considering the ever-increasing importance of indirect taxation as a source of revenue for governments, the intensifying complexity of the legal framework, and the proliferating number of countries adopting indirect taxation, it is essential to scrutinize how the law is applied in practice. The primary driving force in this area is, undoubtedly, the Court of Justice of the European Union. This book analyses selected topics (e.g. fundamental principles and VAT, VAT treatment of financial services, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the Court of Justice of the European Union. Experts from all over the world, not just from academia but also government and judiciary representatives as well as tax practitioners, have provided their input and helped us compile what is an informative and worthy read for anyone dealing with indirect taxation on a professional basis.

Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries. With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.

Basic knowledge of European Tax Law This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. This seventh edition further refines and updates the content, but also enhances the coordination across the chapter and the selection of case law in line with the weight that it carries for the development of European tax law. An indispensable consultation tool - Introduction to European Tax Law on Direct Taxation.

CJEU - The most important cases in the field of direct taxation A great number of cases pending before the European Court of Justice (CJEU) concern the fundamental freedoms and state aid in respect of direct taxation. In particular, the number of infringement procedures brought before the CJEU by the European Commission has been increasing year on year. The CJEU is a driving force in the field of direct tax harmonization. All judgments and pending cases, therefore, have to be carefully analysed by academics as well as practitioners. This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and state aid rules are analysed. The analyses are presented by esteemed national and European tax law experts. The authors focus on the preliminary questions submitted to the CJEU by the national courts and the CJEU case law which could be of relevance for driving future judgments. This book goes to the heart of the national tax systems, exposing hidden obstacles to the fundamental freedoms.

- Kompakte Orientierungshilfe für CISOs, Sicherheitsverantwortliche in Unternehmen, Projektleiter, IT-Berater - Best Practices für die Umsetzung im Unternehmen- Ihr exklusiver Vorteil: E-Book inside beim Kauf des gedruckten BuchesFür Unternehmen ist es existenziell, die Sicherheit ihrer Informationen, Systeme und Produkte zu gewährleisten. Dies trifft heute mehr denn je zu, denn mit zunehmender Vernetzung wächst auch die Angriffsfläche: Jedes vernetzte Gerät ist ein potenzielles Einfallstor für Gefährdungen, und das erhöht das Risiko zusätzlich. Doch wie können Sie Ihr Unternehmen vor diesen Gefährdungen schützen und Sicherheit gewährleisten?Die Antwort auf diese Frage – und viele hilfreiche Impulse und Best Practices – bietet Ihnen dieser Praxisratgeber zum Thema IT-Sicherheit. Es werden alle für Entscheider relevanten Aspekte der IT-Sicherheit beschrieben und das für weiterführende Entscheidungen erforderliche Know-how zielgerichtet vermittelt. Das Buch dient als Leitfaden auf Ihrem Weg zur konsequenten und gleichzeitig effizienten Sicherstellung und Umsetzung von IT-Sicherheit im Unternehmen.Aus dem Inhalt- Ziele von IT-Sicherheit (Vertraulichkeit, Integrität, Verfügbarkeit)- Grundlegende Maßnahmen (Berechtigungen zuteilen, Ausfallplanung, Tests etc.)- Absicherung der IT-Infrastruktur im Unternehmen- IT-Sicherheit in der Cloud- Systematische Umsetzung von Bedrohungs- und Risikoanalysen- Sichere Produktentwicklung- Sicherheit in Produktionsnetzen und -anlagen- Rechtliche Rahmenbedingungen- Organisation des IT-Sicherheitsmanagements im Unternehmen- Sicherheitsstandards und -zertifizierungen- Relevante Wechselwirkungen zwischen Datenschutz und IT-Sicherheit

This handbook is a concise guide for all those who aim at obtaining a basic knowledge of European tax law. Designed for students, it should also be useful for experienced international tax specialists with little knowledge of European law, European law specialists who are reluctant to approach the technicalities of direct taxation and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. This book should also help academics without a legal background to approach the technical issues raised by European Union tax law.This edition contains selected relevant information available as of 30 June 2022. It retains all of the features and tools contained in the previous editions (including the final charts, which our readers very much appreciate). In this edition the authors have also included a list of relevant documents and a selection of reference textbooks on European tax law in five languages, of potential interest to readers.

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing's interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Tax tech companies are rapidly gaining ground as global tax advisory firms, and are set to fundamentally change and revolutionize the way tax administrations, taxpayers, and their advisers interact, ushering in a much more efficient and effective integration of tax services into the processes used by both taxpayers and tax authorities. The distinguished contributors to this book clearly explain not only how tax law can be revised to promote digitization and speed up its implementation but also how to achieve better tax compliance and administration at a lower cost. The authors cover such aspects of this veritable paradigm shift in tax management as the following: how new technologies improve existing VAT/GST systems; uses of artificial intelligence; secured certification of taxpayers; electronic invoices; securing real-time reporting with cryptography; taxing virtual currencies; enhanced personal data protection; fewer opportunities to engage in aggressive tax practices; competitive advantage in attracting investment; work-flow assessment; and more opportunities for information flows and collaboration. Because the perspective as to what is meant by tax compliance is already overlaid by technological pressure—as indicated especially by BEPS 1.0's domestic tax law initiatives and its recommendations of newly developed options to secure full transparency of tax processes—it is clear that controls and tax risk management are on the rise and that systems will become more digitized. For these reasons, professionals in the tax advisory industry and tax authority officials will welcome this book's sound and practical measures leading to progress and revitalization through digital transformation.

Information Law Series #48 About this book: Imposing Data Sharing among Private Actors is a vital book shedding light on the nature of certain economic and societal balancing exercises required for any compulsory business-to-business (B2B) data-sharing initiatives because data sharing involves both benefits and potential costs. While the economic value originating from data sharing seems evident, identifying the legal framework to be applied to it is a challenge. This is due to the multiple claims and rights aimed at controlling, accessing or benefiting from data processing. What's in this book: Whether these initiatives pursue economic, societal or empowerment objectives, their potential benefits must be balanced with the following three considerations that are extensively investigated in the book: the economic interests of the data holder; personal data protection considerations; and long-term and collective costs in terms of individual autonomy. The analysis elucidates how these aspects have been factored into existing compulsory B2B data-sharing initiatives so far (particularly in Europe), and on how they may be used as a source of inspiration in future initiatives. Insightful suggestions on the implementation of these balancing exercises conclude the volume. How this will help you: Based on law and literature in competition, personal data protection and intellectual property, the book greatly highlights the necessary balances underlying compulsory B2B data sharing and raises awareness about the crucial need to take the risks involved into consideration. It will be highly appreciated by policymakers, academics and private actors interested in issues linked to competition law in the digital environment, regulation of platforms, data governance or the interaction between competition law and personal data protection law.

CJEU - The most important cases in the field of direct taxation A great number of cases pending before the Court of Justice of the European Union (CJEU) concern the fundamental freedoms and direct taxation. In particular, the number of infringement procedures brought before the CJEU by the European Commission has been increasing year on year. The CJEU is still in the driver´s seat in the area of direct taxation. All judgements and pending cases, therefore, have to be carefully analyzed by academics as well as practitioners. This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and secondary EU law are analyzed. The analyses are presented by esteemed national and European tax law experts. By examining the preliminary questions, the arguments brought forward by the parties and existing CJEU case law, the authors provide insight into the possible reasoning of the Court. Moreover, this book goes to the heart of the national tax systems, exposing hidden obstacles to the fundamental freedoms.

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries'legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers seven topic-based papers prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on the Tax Challenges of the Digitalization of the Economy. Recent Developments on Transfer Pricing and COVID-19. Recent Developments on Transfer Pricing and Simplification Measures. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analysed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm's length principle and its application; the consequences of a transaction not being in accordance with the arm's length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students - irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD´s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.

This book provides an overview of the positions and experiences of 34 select countries with regard to the impact of the MLI on their tax treaty network.

Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, states have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This book provides an introduction to the law of double taxation conventions. Although principally aimed at students, irrespective of their national background, the book will be of value to tax experts who wish to learn more about double taxation conventions, as well as international law experts who wish to gain a better understanding of tax law. The book does not consider one jurisdiction in particular, but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. This revised edition takes into account new developments that have occurred since the previous edition of 2013, in particular the changes through OECD's BEPS Project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries (both published in 2017), as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.

A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties,'Tax Treaty Case Law around the Globe 2020'is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

This handbook is a concise guide for all those who aim at obtaining a basic knowledge of European tax law. Designed for students, it should be useful as well for experienced international tax specialists with little knowledge of European law and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. The fourth edition contains changes that include: an enhanced analysis of the implications of the EU Charter of Fundamental Rights for direct taxes; a new chapter on European tax coordination; a focused analysis of the implications of BEPS and tax transparency for EU tax law; and a stronger emphasis of developments in the field of State aids.

A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

Attribution of Profits to Permanent Establishments: Issues and Developments The profit attribution to permanent establishments is one of the most controversial topics in international tax law. In recent years it was subject to various changes based on the introduction of the'Authorized OECD Approach'in 2008 and 2010, the outcomes of Final Report on OECD BEPS Action 7 and the Final Report on'Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7'from 2018 (with the previous Discussion-Drafts). This publication discusses the most important issues and recent developments related to the attribution of profits to permanent establishments. Starting with an in-depth analysis on the commonalities and differences between the profit attribution provisions in modern double tax treaties (ie Art 7 AOA vs Art 9 OECD/UN Models), it further deals with topics such as profit attribution to PEs and PE exemptions (Art 5 para 4), profit attribution to agency PEs (Art 5 para 5 and 6), and profit attribution to a'significant economic presence'and to market states. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium that took place in October 2019 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the opinions on the issues at stake of representatives of tax administrations, multinationals and tax advisories, which completes this essential practical guideline.

The most important and recent judgments of the CJEU Considering the ever increasing importance of indirect taxation as a source of revenue for governments, the intensifying complexity of the legal framework, and the proliferating number of countries adopting indirect taxation, it is essential to scrutinize how the law is actually applied in practice. The primary driving force in this area is, undoubtedly, the Court of Justice of the European Union. This book analyses selected topics (e.g. fundamental principles and VAT, administrative cooperation in VAT, taxable base and rates, exemptions, and deductions) by examining the most prominent and recent judgments of the Court of Justice of the European Union. Experts from all over the world, not just from academia but also government representatives and tax practitioners, have provided their input and helped us compile what is an informative and worthy read for anyone dealing with indirect taxation on a professional basis.

The design of international tax law cannot be described without recourse to its extensive history. By looking at the evolution of tax treaties, valuable insight is gained as regards the causes behind the most recent shift towards renewed international tax coordination in the framework of the BEPS Project. This book analyses how tax treaties have evolved, from the early days of the history of international taxation until the beginning of the BEPS era, by collecting the outcome of joint research on the development of international tax law. It consists of a wide range of papers bridging the existing gap between the history of international law, economic history and the history of international cooperation. In this context, it also spells out the importance of the role of early institutions such as the International Chamber of Commerce and the League of Nations, as well as the International Fiscal Association and the OEEC/OECD, and helps to highlight their fundamental influence. The book is the result of the conference “History of Double Taxation Conventions”, which took place from 3-5 July 2008 in Rust/Neusiedler See. It consists of 30 contributions exploring the development of the tax treaty practices of 30 countries and, additionally, three cross-sectional contributions.

Controlled foreign company legislation is an international tax topic that has become increasingly important in recent years. Both the OECD and the European Union have taken initiatives to introduce controlled foreign company rules as anti-avoidance tax provisions that are applicable by a large number of states. The OECD released its recommendations on strengthening controlled foreign company rules in the Base Erosion and Profit Shifting Project Action 3 Final Report. The European Union consequently adopted Council Directive 2016/1164, laying down rules against tax avoidance practices that directly affect the functioning of the internal market and introducing the obligation for Member States to implement controlled foreign company rules in their domestic legislation. The aim of this book is to provide tax authorities, policymakers, courts and practitioners with an overview of the effectiveness of controlled foreign company rules and the approach towards recent amendments in the participating countries introducing or changing such rules. The book comprises 41 national reports from countries across the globe and is the outcome of a conference on controlled foreign company legislation that took place from 4-7 July 2019 in Rust (Austria). More than 100 experts, including the authors of the national reports, were brought together to discuss recent developments in the field of controlled foreign company legislation. A general report highlights the most important findings of the conference.

This volume features a collection of papers on emerging concepts, significant insights, novel approaches and ideas in information systems development (ISD). It xamines advances in ISD in general and investigates emerging trends that will shape the ISD research agenda beyond 2020. The book gathers selected papers from the 28th International Conference on Information Systems Development held in Toulon, France on August 28-30, 2019.The revised and extended papers explore the mutual influences between information systems and organizational structures, processes and people, and promote research into methodological issues and ways in which the IS designers and developers are transforming organizations and society through information systems.Chapter'Smart Grid Challenges through the lens of the European General Data Protection Regulation'is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries'legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

Basic knowledge of European Tax Law This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. This sixth edition further refines and updates the content, but also enhances the coordination across the chapter and the selection of case law in line with the weight that it carries for the development of European tax law.

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 41 most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.