Principles of International Taxation

Principles of International Taxation
Author: Lynne Oats
Publisher: Bloomsbury Publishing
Total Pages: 709
Release: 2021-09-30
Genre: Business & Economics
ISBN: 1526519577

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.

Basic International Taxation

Basic International Taxation
Author: Roy Rohatgi
Publisher:
Total Pages: 467
Release: 2005
Genre: Double taxation
ISBN: 9781904501343

This book provides a comprehensive overview of the basic principles of international taxation and considers these in the context of practical planning guidance. Volume 1 (Principles), gives an overview of international taxation, principles of international tax law, model tax conventions on double tax avoidance, and the impact of domestic tax systems. Volume 2 (Practice), deals with the practice of international taxation including international tax planning techniques, basic isssues in anti-avoidance and gives an overview of the international offshore financial centres.

The Public International Law of Taxation

The Public International Law of Taxation
Author: Asif H. Qureshi
Publisher: Kluwer Law International B.V.
Total Pages: 912
Release: 2019-05-22
Genre: Law
ISBN: 9041184775

The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.

International Tax Policy

International Tax Policy
Author: Tsilly Dagan
Publisher: Cambridge University Press
Total Pages: 263
Release: 2018
Genre: Business & Economics
ISBN: 1107112109

Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.

International Law of Taxation

International Law of Taxation
Author: Peter Hongler
Publisher: Oxford University Press
Total Pages: 289
Release: 2021
Genre: Law
ISBN: 019289871X

In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.

International Tax Policy and Double Tax Treaties

International Tax Policy and Double Tax Treaties
Author: Kevin Holmes
Publisher: IBFD
Total Pages: 433
Release: 2007
Genre: Double taxation
ISBN: 9087220235

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

International Company Taxation

International Company Taxation
Author: Ulrich Schreiber
Publisher: Springer Science & Business Media
Total Pages: 179
Release: 2013-01-30
Genre: Business & Economics
ISBN: 3642363067

The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

The Principles of International Tax

The Principles of International Tax
Author: Adrian Ogley
Publisher: International Information Services Incorporated
Total Pages: 186
Release: 1993
Genre: Business & Economics
ISBN: 9780952044208

This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.

Permanent Establishment

Permanent Establishment
Author: Arvid Aage Skaar
Publisher: Kluwer Law International B.V.
Total Pages: 999
Release: 2020-06-19
Genre: Law
ISBN: 9403520647

A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.

Global Perspectives on Income Taxation Law

Global Perspectives on Income Taxation Law
Author: Reuven Shlomo Avi-Yonah
Publisher: Oxford University Press, USA
Total Pages: 202
Release: 2011
Genre: Law
ISBN: 0195321367

In Global Perspectives on Income Taxation Law, Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class. It is arranged by subject matter in the order in which they are usually covered in U.S. tax law classes. The materials are drawn from a wide variety of countries, including developing countries.