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International Taxation of Banking

International Taxation of Banking

Author: John Abrahamson
Publisher: Kluwer Law International
ISBN: 9789403510941
Published In: February 2020
Format: Hardback
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details
About this book:

International Taxation of Banking introduces and analyses the international tax issues which relate to international banking activities. Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups.

What’s in this book:

The content of this book clearly identifies and explains the management of research and development and intangible property used in the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book examines such issues as the following:
- taxation of dividends and branch profits derived from other countries;
- transfer pricing and branch profit attribution;
- taxation of global trading activities;
- tax risk management;
- provision of services and intangible property within multinational groups;
- taxation treatment of research and development expenses;
- availability of tax incentives such as patent box tax regimes;
- swaps and other derivatives;
- loan provisions and debt restructuring;
- financial technology (FinTech);
- group treasury, interest flows, and thin capitalisation;
- tax havens and controlled foreign companies; and
- taxation policy developments and trends.
Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail.

How this will help you:

The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will serve as an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Preface

List of Abbreviations

CHAPTER 1
Introduction

CHAPTER 2
The Banking Regulatory Framework

CHAPTER 3
Retail and Commercial Banking

CHAPTER 4
Investment Banking

CHAPTER 5
Introduction to International Tax

CHAPTER 6
Tax Treaties

CHAPTER 7
OECD BEPS Developments

CHAPTER 8
Bank Parent Companies

CHAPTER 9
Bank Branches

CHAPTER 10
Other Bank Permanent Establishments

CHAPTER 11
Representative Offices

CHAPTER 12
Derivatives

CHAPTER 13
Loan Provisions and Debt Restructuring

CHAPTER 14
Value Added Tax: VAT

CHAPTER 15
Bank Taxes: Financial Transaction Taxes and Bank Levies

CHAPTER 16
Dividends and Profit Distributions

CHAPTER 17
Group Treasury, Interest Flows and Thin Capitalisation

CHAPTER 18
Intangible Property: IP

CHAPTER 19
Tax Havens and Controlled Foreign Companies: CFCs

CHAPTER 20
Introduction to Transfer Pricing

CHAPTER 21
Transfer Pricing and Bank Branch Attribution

CHAPTER 22
Transfer Pricing and Global Trading

CHAPTER 23
Transfer Pricing and Loans

CHAPTER 24
Transfer Pricing and Intangibles

CHAPTER 25
Transfer Pricing and Services

CHAPTER 26
Islamic Banking

CHAPTER 27
Green Banking

CHAPTER 28
Microfinance Banking

CHAPTER 29
Financial Technology: Fintech

CHAPTER 30
Shadow Banking

CHAPTER 31
Automatic Exchange of Information: CRS and FATCA

CHAPTER 32
Taxation Policy Developments

CHAPTER 33
General Conclusions

Case Studies

Case Study 1
The Malaysia Branch: Permanent Establishments and Treaties

Case Study 2
The Korean Bank Acquisition: Group Interest Deductions

Case Study 3
Group Technology: Global Risk Management Cloud Software and Tax Treaties

Case Study 4
The Italian Branch: Branch Attribution

Case Study 5
Branch Profit Attribution: Corporate Loans and Global Trading

Case Study 6
The Group Advertising Centre: Transfer Pricing Dispute

Appendix
OECD Model Tax Convention 2017

Table of Cases

Table of Statutes and Directives

Table of Treaties and International Agreements

Index