Tolley's International Tax Planning 2011-12

International tax planning is an increasingly important issue, no longer the preserve of the Big 4 and their large multinational clients but important also for smaller businesses and their advisors.

This extensive work on International Tax Planning, written by a team of experts, covers all the main issues in international tax planning, including Controlled Foreign Companies, EU Law, Double Tax Relief, Withholding Taxes and Transfer Pricing. Tolley's International Tax Planning provides thorough coverage of the topic in an easy-to-use format, including a series of transactional-driven case studies and an overview of overseas tax systems. Each key topic is illustrated with short examples, tables and checklists for effective tax planning.

New to Tolley's International Tax Planning 2011-12:

• Tax planning roadmaps to support the case studies – providing a checklist of issues to consider and cross-references to the relevant parts of the book
• New business migration planning ideas
• New debt cap planning ideas
• Clear coverage of basic principles, practical situations and typical planning structures
• Basic principles and planning opportunities arising from the new branch profits exemption
• New chapters on investing in the US, China and India

Technical updates to Tolley’s International Tax Planning include:

• The Dell and Zimmer cases on commissionaire structures
• Controlled foreign company reform
• Branch profits exemption
• Treatment of software distribution agreements with particular focus on recent cases in Russia, India and Australia
• 2010 update to the OECD model tax treaty and commentary

New checklists and flowcharts including:

• Steps to avoid a permanent establishment
• A summary of the time periods for creating a construction site permanent establishment under the UK’s double tax agreement
• Limitation on Benefits article in the UK/US double tax agreement
• Controlled foreign company transitional rules