Principles of international taxation.

Principles of international taxation.

by Millerˌ A., Oatsˌ L.

Type Book
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Summary

This book provides an introduction to international taxation. The book presents its material in a global context, explaining the variety of approaches used around the world to deal with central issues that arise in international tax. It covers the basics on double tax relief, gives an introduction to double tax treaties and their use. Covers the fundamental issues of transfer pricing. Looks at the types of tax planning undertaken by multinational groups of companies to minimise the tax burden. It looks at the measures being taken by governments to prevent tax avoidance and evasion through the use of tax havens: controlled foreign company legislation; developments in information exchange and assistance in collection of tax such as FATCA, the OECD's Common Reporting Standards and the EU Development Assistance Committee (DAC). It further covers the OECD's initiative to curb base erosion and profit shifting, including the Final reports issued in October 2015. Examines the problems and tax liabilities encountered when providing cross-border services, including the planned new article in the 2016 UN Model Tax Convention permitting withholding tax on technical service fees. It also looks at the international tax aspects of group financing, hybrid entities and hybrid financial instruments, and the restrictions on deductibility of interest. Finally it covers recent case law on permanent establishments, entity characterisation, transfer pricing and limitation of benefits.

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Titles

  • Full Title: Principles of international taxation.

Edition Statement

  • 5th ed.

Notes

  • Also available: 1st (2006), 2nd (2009), 3rd (2012) and 4th (2014)ed. - Includes glossary and index.
  • English.

Identifiers

  • Isbns: 9781780437859; 1780437854
  • Oclc Number: (OCoLC)950067061

Publication Statement

  • Place: Haywards Heath
  • Publisher: Bloomsbury Professional
  • Date: 2016

Physical Description

  • Extent: 912

Summary

  • This book provides an introduction to international taxation. The book presents its material in a global context, explaining the variety of approaches used around the world to deal with central issues that arise in international tax. It covers the basics on double tax relief, gives an introduction to double tax treaties and their use. Covers the fundamental issues of transfer pricing. Looks at the types of tax planning undertaken by multinational groups of companies to minimise the tax burden. It looks at the measures being taken by governments to prevent tax avoidance and evasion through the use of tax havens: controlled foreign company legislation; developments in information exchange and assistance in collection of tax such as FATCA, the OECD's Common Reporting Standards and the EU Development Assistance Committee (DAC). It further covers the OECD's initiative to curb base erosion and profit shifting, including the Final reports issued in October 2015. Examines the problems and tax liabilities encountered when providing cross-border services, including the planned new article in the 2016 UN Model Tax Convention permitting withholding tax on technical service fees. It also looks at the international tax aspects of group financing, hybrid entities and hybrid financial instruments, and the restrictions on deductibility of interest. Finally it covers recent case law on permanent establishments, entity characterisation, transfer pricing and limitation of benefits.

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