International Tax Primer, 2nd Edition

Taxation

International Tax Primer, 2nd Edition

Edited by Brian J. Arnold · Michael J. Mcintyre
Kluwer Law International October 2002

Specifications

ISBN-13
9789041188984
Publisher
Kluwer Law International
Publication
October 2002
Format
Paperback , 196 pages
Jurisdiction
International ? Countri(es) for reference only

Details

The international aspects of income taxation have become increasingly important as countries worldwide have become more economically integrated. International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. It grew out of the authors' work with the OECD in conducting seminars on international tax for tax officials in countries emerging from the collapse of the Soviet Union.

The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes:

  • the role of the tax adviser;
  • tax planning techniques;
  • international double taxation;
  • transfer pricing; anti-avoidance rules;
  • tax treaties, including discussion of the OECD and UN Model Treaties;
  • emerging issues, such as e-commerce and harmful tax competition.

 

Table of Contents

Preface

Chapter 1. Introduction

A. Objectives of this Primer

B. What is International Tax?

C. Goals of International Tax Rules

D. The Role of the Tax Adviser in Planning International Transactions

Chapter 2. Jurisdiction to Tax

A. Introduction

B. Defining Residence

C. Source Jurisdiction

Chapter 3. Double Taxation Relief

A. Introduction

B. International Double Taxation Defined

C. Relief Mechanisms

D. Allocation of Expenses

E. Tax Sparing

Chapter 4. Transfer Pricing

A. Introduction

B. Arm’s Length Method

C. Determining the Income of a Branch or Permanent Establishment of a Corporation

D. Formulary Apportionment and the Future of the Arm’s Length Method

Chapter 5. Anti-Avoidance Measures

A. Introduction

B. Thin Capitalization Rules

C. Controlled Foreign Corporation (CFC) Rules

D. Offshore Investment Funds

Chapter 6. Tax Treaties

A. Overview

B. Contents of a Typical Tax Treaty

C. Special Treaty Issues

Chapter 7. Emerging Issues

A. Harmful Tax Competition

B. Hybrid Entities

C. Electronic Commerce

Glossary of International Tax Terms, Selected Bibliography, Index

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