IFA: Abusive Application of International Tax Agreements by International Fiscal Association
This Seminar focused not only on the technical consideration of Secondary Aspects but also on the underlying philosophical question: namely, should secondary adjustments be employed at all and, if so, what are the appropriate limitations on their use? While a 'corresponding adjustment' may be appropriate in order to avoid double taxation, other secondary adjustments, such as conforming adjustments' and reclassification of income' are more problematic. The Panellists and audience were asked to consider the implications of secondary adjustments in the context of tax compliance, tax administration, and private contracts. Is it appropriate for the tax administrator to intervene in private transactions to the extent of deeming' a capital contribution or deeming' a dividend? In this book you will be introduced to a labyrinth of potential adjustments that could flow from the primary transfer pricing adjustment. A glossary of terms is provided to assist the reader in sorting through the maze. You will learn about set-offs and corresponding adjustments as well as about secondary adjustments, such as reclassification of income. Following the outline are examples and diagrams that explicate the principles explained in the outline, as well as papers prepared by individual panellists.| SKU | Unavailable |
| ISBN 13 | 9789041116734 |
| ISBN 10 | 9041116737 |
| Title | IFA: Abusive Application of International Tax Agreements |
| Author | International Fiscal Association |
| Series | Ifa Congress Series Set |
| Condition | Unavailable |
| Binding Type | Paperback |
| Publisher | Kluwer Law International |
| Year published | 2001-10-01 |
| Number of pages | 98 |
| Cover note | Book picture is for illustrative purposes only, actual binding, cover or edition may vary. |
| Note | Unavailable |