Principles of international taxation

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The item Principles of international taxation represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: This book provides an introduction to international taxation. It presents its material in a global context, explaining the variety of approaches used around the world to deal with the central issues that arise in international tax. It covers the basics of key international tax concepts including double taxation and its relief. Furthermore, it gives an introduction to double tax treaties and their use including the OECD, UN and US models. It also covers: fundamental principles of transfer pricing; types of tax planning undertaken by multinational groups of companies to reduce the global tax burden; international tax aspects of group financing, hybrid entities, hybrid financial instruments and restrictions on deductibility of interest. The book also examines the OECD's initiative to curb base erosion and profit shifting, including the multilateral instrument (MLI), changes to the OECD Model and the transfer pricing guidelines. It looks into the measures taken by governments to prevent tax avoidance and evasion through the use of tax havens: controlled foreign company (CFC) legislation, exchange of information, assistance in collection of tax such as FATCA, OECD's Common Reporting Standard, and transparency initiatives including country by country reporting. Finally, it provides recent case law on permanent establishments (PEs), entity characterization, transfer pricing and limitation of benefits

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Summary: This book provides an introduction to international taxation. It presents its material in a global context, explaining the variety of approaches used around the world to deal with the central issues that arise in international tax. It covers the basics of key international tax concepts including double taxation and its relief. Furthermore, it gives an introduction to double tax treaties and their use including the OECD, UN and US models. It also covers: fundamental principles of transfer pricing; types of tax planning undertaken by multinational groups of companies to reduce the global tax burden; international tax aspects of group financing, hybrid entities, hybrid financial instruments and restrictions on deductibility of interest. The book also examines the OECD's initiative to curb base erosion and profit shifting, including the multilateral instrument (MLI), changes to the OECD Model and the transfer pricing guidelines. It looks into the measures taken by governments to prevent tax avoidance and evasion through the use of tax havens: controlled foreign company (CFC) legislation, exchange of information, assistance in collection of tax such as FATCA, OECD's Common Reporting Standard, and transparency initiatives including country by country reporting. Finally, it provides recent case law on permanent establishments (PEs), entity characterization, transfer pricing and limitation of benefits

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