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International Tax as International Law

International Tax as International Law An Analysis of the International Tax Regime

Name: International Tax as International Law
Brand: Cambridge University Press
SKU: 9780521618014
Price: 491.66 HKD
Availability: OutOfStock
Author: Reuven Avi-Yonah
ISBN: 9780521618014

By Reuven Avi-Yonah

Cambridge University Press October 2007

Specifications

ISBN-13: 9780521618014
Publisher: Cambridge University Press
Publication: October 2007
Format: Paperback
Jurisdiction: International, U.S. ? Countri(es) for reference only

Details

This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time.

Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how U.S. tax law embodies the underlying norms of the regime.

Contents:: 1. Introduction: Is there an international tax regime? Is it part of international law?; 2. Jurisdiction to tax; 3. Sourcing income and deductions; 4. Taxation of non-residents: investment income; 5. Taxation of non-residents: business income; 6. Transfer pricing; 7. Taxation of residents: investment income; 8. Taxation of residents: business income; 9. The tax treaty network; 10. The tax arbitrage, tax competition, and the future of the international tax regime.