THE EU AND SUPRANATIONAL ORGANISMS TAX POLICY MANUAL

THE EU AND SUPRANATIONAL ORGANISMS TAX POLICY MANUAL

Author: Piergiorgio Valente

The EU and Supranational Organisms Tax Policy Manual intends to provide a concise and comprehensive picture of the developments on the tax treatment of legal entities within the framework of the EU and of the main Supranational Organisms (the OECD among these).

The text mainly addresses measures adopted at both, EU and international level, to counteract the double taxation phenomenon, which is historically deemed one of the major obstacles hindering EU entrepreneurial activities abroad.

The work puts special focus on developments witnessed in the last few years vis-à-vis the struggle against tax evasion, the latter being a crucial issue which has come under the spotlight of the international scenario, while giving due account of the most recent studies and further in-depth analyses conducted on such theme by the OECD (so-called BEPS Project).

The Manual, mainly addressed to students, stands out for its brilliant approach to the subject-matter and prompt identification of important contents.

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INTERNATIONAL TAX AVOIDANCE

INTERNATIONAL TAX AVOIDANCE

Author: Piergiorgio Valente

Tax planning and the pursuit of an advantageous position from a tax point of view are not inherently illegal activities. It is, however, necessary to identify the boundaries between what can be considered a legitimate tax saving and what should fall within the concept of "tax avoidance" (which is deemed pathological and, thus, is to counteract). In recent years, moreover, the erosion of the tax base due to the artificial transfer of profits toward jurisdictions with more favorable tax regimes (so-called BEPS) is a source of particular concern for States. This debate, of high relevance at the international level, aims to identify effective tackling measures in all sectors concerned, in order to safeguard the tax interests of States with advanced tax regimes.

The book "International Tax Avoidance" aims to provide a comprehensive framework meeting the needs of those who deal with the issue of tax avoidance, providing insights and practical application concepts useful for advisors, businesses, and Tax Authorities.

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DELOCALIZATION, CORPORATE MIGRATION, AND TRANSFER OF HEADQUARTERS

DELOCALIZATION, CORPORATE MIGRATION, AND TRANSFER OF HEADQUARTERS

Authors: Piergiorgio Valente and Raffaele Rizzardi

"Delocalization, Corporate Migration, and Transfer of Headquarters" addresses civil law, accounting, and tax issues arising from the moving abroad of companies’ registered offices or related to the choice of the place of "delocalization" itself. The discussion of the transfer of the registered office of a foreign company in Italy and, vice versa, of the transfer of the headquarters of an Italian company abroad, is made in light of recent legislative and case law developments at the national, international, and EU level. 
The book also analyzes corporate reorganizations carried out by multinational companies from a "functional" point of view, taking into account the work of the OECD on base erosion and profit shifting and the EU tools aimed at encouraging this type of operations that are available totaxpayers.

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WORKERS ABROAD: Tax, Labor, and Social Security Aspects

WORKERS ABROAD: Tax, Labor, and Social Security Aspects

Authors: Piergiorgio Valente, Salvatore Mattia and Paola Salazar

In the current globalized economic context, managing the relocation of employees abroad is an essential issue that multinational enterprises have to face. This volume identifies the main modalities through which employees' relocation, transfer or secondment may be carried out by describing contractual norms, labor law and social security issue, with reference to national laws as well as international principles and regulations.

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INTERNATIONAL TAX DISPUTES: Mutual Agreement Procedures and Relations Management

INTERNATIONAL TAX DISPUTES: Mutual Agreement Procedures and Relations Management

Authors: Piergiorgio Valente, Caterina Alagna and Salvatore Mattia

Multinational companies are increasingly exposed to the risk of double taxation due to transfer pricing-related tax adjustments following assessments by Tax Authorities.
The use of specific procedures to solve international tax disputes, in particular those described in Art. 25 of the OECD Model Tax Convention and the Arbitration Convention 90/436/EEC, requires an accurate evaluation of they relate to internal administration and jurisdiction processes.

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EXCHANGE OF INFORMATION TAX ASSESSMENTS: Practical Considerations

EXCHANGE OF INFORMATION TAX ASSESSMENTS: Practical Considerations

Authors: Piergiorgio Valente and Luigi Vinciguerra

The use of artificial structures or "constructions" and the exploitation of "disharmony" existing between national laws have the effect of exacerbating the loss of tax revenue. The fight against tax evasion and aggressive tax planning schemes requires joint coordinated interventions aimed at facilitating access to information on cash flows and traceability of payments. In order to achieve this, tax systems transparency, the elimination of banking secrecy, and administrative cooperation between States play a key role.
The implementation of the exchange of information, in all its forms (on request, automatic, spontaneous, etc.), represents the most effective response to practices that undermine tax bases and tax revenues.

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HIDDEN PERMANENT ESTABLISHMENT TAX ASSESSMENTS: Practical Considerations

HIDDEN PERMANENT ESTABLISHMENT TAX ASSESSMENTS: Practical Considerations

Authors: Piergiorgio Valente and Luigi Vinciguerra

Non-resident foreign entities producing corporate income on Italian territory may register as permanent establishments (thus becoming fully subject to taxation in Italy) or may take a series of actions leading to the creation of “hidden” permanent establishments, as they operate within Italian legal entities partially-owned by foreign companies or bodies.
To eliminate this risk, each company should carry out accurate analyses and identify and abide by specific guidelines.

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