International Company Taxation and Tax Planning

This unique title provides in-depth description and analysis of tax systems worldwide. Combined with practical guidance on international planning approaches from a team of both tax practitioners and academics, this title will enhance planning for optimal specific arrangements in each cross-border business operation.

In addition to frequent references to country-specific tax legislation — including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere – the book discusses important ECJ decisions and numerous other case studies.

Gain full understanding with specific guidance on the following areas of international taxation:

• sources of tax legislation;
• role of bilateral tax treaties;
• determination of taxable income;
• tax collection, enforcement, and compliance;
• elimination of double taxation;
• treatment of losses;
• pass-through taxation vs. separate entity approach;
• tax burden at the corporate and shareholder levels;
• inheritance tax;
• harmonized VAT in the EU;
• allocation of functions, risks, assets, and capital;
• target variables for international tax burden comparisons;
• cross-border leasing;
• tax structuring for mergers and acquisition;
• tax management of intellectual property; and
• the proposed EU Common Consolidated Corporate Tax Base (CCCTB).

International Company Taxation and Tax Planning by Dieter Endres and Christoph Spengel will be welcomed by practitioners engaged in the field of international taxation, whether they work in companies, law firms, or government. Interested academics will find here an unmatched comparative analysis of the global web of international taxation law and practice.