Internal Revenue Bulletin

Internal Revenue Bulletin
Author: United States. Bureau of Internal Revenue
Publisher:
Total Pages: 1998
Release: 1958
Genre: Tax administration and procedure
ISBN:

International Taxation of Cross-border Leasing Income

International Taxation of Cross-border Leasing Income
Author: Amar Mehta
Publisher: IBFD
Total Pages: 307
Release: 2005
Genre: Corporations, Foreign
ISBN: 9076078718

This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.