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The notion of 'substance' is proving to be central to the OECD's base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership).
In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions:EXTRA 15 % nuolaida su kodu: ENG15
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The notion of 'substance' is proving to be central to the OECD's base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership).
In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions:
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