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x, 185 p. ; 24 cm.
This text 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 emphasizes tax treaties and other co-operative arrangements that countries employ to co-ordinate their income tax systems with the tax systems of their trading partners, aiming to strike 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. It should work as both an introduction and a refresher in an area where issues often prove more complex than they seem and where a return to the basics is often the most helpful means of untangling a multi-layered problem. The second edition provides updates for recent developments and expands the coverage by providing many new examples. A chapter dealing with harmful tax competition, hybrid entities, and the taxation of e-commerce has been added to the book.
(source: Nielsen Book Data)9789041188984 20160528
Law Library (Crown)
xiii, 256 p. ; 25 cm.
Law Library (Crown)
xi, 352 p. ; 21 cm.
Law Library (Crown)
iv, 111 p. : map ; 28 cm.
Green Library
iv, 111 p. : map ; 28 cm.
Law Library (Crown)
xxiii, 328 pages : illustrations ; 25 cm.
  • Fundamentals and objective
  • Source taxation of business profits according to the OECD model
  • Source taxation of business profits from a national point of view of Germany, the US and the BRIC states
  • Cross-country analysis of the OECD and national PE concepts and the rules on the attribution of business income
  • Reform proposals with regard to the PE definition and the attribution of business profits
  • Final conclusion in the form of theses.
"The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE definition and the allocation of profits between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specific source taxation rules, focusing on possible tax system changes and offering reform proposals. Ensuring the taxable implications of the various rules upon country-specific PE concepts, the author's treatment covers such issues and topics as the following: the PE definition of the OECD MC and from the perspective of selected countries; allocation of business profits under the authorised OECD approach (AOA); avoidance of PE status; implementation of a service PE proposal; construction site PEs established by subcontractors; existence of an agency PE; and the OECD project on base erosion and profit sharing (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualification conflicts, thus reinforcing his detailed discussion of source taxation rules of business profits and relevant case law in Germany, the United States, and the BRIC states. This book discusses qualification conflicts of PE taxation in cross-border cases and analyses risks of double and non-taxation and increasing complexity. There is also a checklist detailing how companies can avoid unintentionally setting up a PE."-- Back cover.
Law Library (Crown)
xii, 230 pages : illustrations ; 24 cm
  • Introduction
  • Jurisdiction to tax
  • Taxation of residents
  • Double taxation relief
  • Taxation of nonresidents
  • Transfer pricing
  • Anti-avoidance measures
  • An introduction to tax treaties
  • Emerging issues.
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. This third edition has been expanded substantially, as a result of major developments that have occurred since the second edition of this indispensable resource appeared in 2004 - not least due to the fact that innumerable small and medium-sized firms, as well as individuals, now engage in cross-border transactions that require they, and their tax advisers to confront international tax issues on a regular basis. This book aims to strike 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.
Law Library (Crown)
1 volume (various pagings) ; 25 cm
  • Permanent Establishment in the OECD Model Tax Convention / Ekkehart Reimer
  • Australia / Peter Collins & Hamish McElwee
  • Austria / Herbert Greinecker & Gülay Karatas
  • Belgium / Pascal Janssens, Bertrand Vandepitte & Sofie Van de Perre
  • China / Matthew Mui & Alan Yam
  • Denmark / Søren Jesper Hansen, Elizabeth Brandt & Lene Munk Rasmussen
  • Estonia / Iren Koplimets & Karl-Rauno Miljand
  • France / Renaud Jouffroy & Emmanuel Raingeard de la Blétière
  • Germany / Claus Jochimsen & Maximilian Schrepfer
  • Hungary / Ákos Burján & Ibolya Tóth
  • India / Ketan Dalai, Vishal J. Shah & Smit Sheth
  • Italy / Fabrizio Acerbis & Francesco Nuzzolo
  • Japan / Yoshiyasu Okada & Yumiko Arai
  • The Netherlands / Suzanne Boers, Hein Vermeulen & Ciska Wisman
  • Russia / Mikhail Filinov, Valeria Lukina, Boris Ostrovskiy & Dmitriy Yasnovskiy
  • South Africa / David Lermer, Johann Hattingh & Chris de Bruyn
  • Spain / Ramón Mullerat & Anna Mallol
  • Sweden / Gunnar Andersson & Carl Wattrang
  • Switzerland / Stefan Schmid & Marianne Orell
  • United Kingdom / Peter Cussons & Chloë Paterson
  • United States / Oren Penn, Stephen Nauheim & Daniel Rinke.
Law Library (Crown)
234 p. : ill. ; 25 cm.
  • Section 1 - introduction to international tax planning for US MNCs: introduction-- holding companies as key international tax planning tools-- basic concepts of US federal income taxation. Section 2 - tax planning goals: avoidance and minimization of foreign withholding taxes-- deduction of expenses-- immediate utilization of losses. Section 3 - tax planning tools: routing of income-- conversion of income-- classification of entities (check-the-box regulations). Section 4 - tax planning barriers (subpart F): purpose and tax consequences-- requirements-- impacts FTCs-- conclusion. Section 5 - specific tax planning techniques: country-by-country synopsis - Austria, Belgium, Denmark, France, Germany, Ireland, Luxembourg, The Netherlands, Spain, Switzerland, summary table-- new Luxembourg/US income tax treaty-- double dip-- achieving full FTC by issuing a hybrid instrument-- shifting income to low-tax jurisdictions-- achieving tax-exempt capital gains-- new UK onshore pooling provision-- Span as a gateway to Argentina-- EU enlargement. Section 6 - future developments and summary: the department of the treasury subpart F study-- harmful tax competition-- EU internal market without tax obstacles and EU company taxation-- European company (the so called Societas Europaea)-- summary.
  • (source: Nielsen Book Data)9789041199225 20160528
The complexity of taxation exceeds all bounds when fastened to a multinational corporation (MNC). In a maze of rules that are always changing, a tax practitioner in the MNC landscape must be extremely well informed and ready to act with sound strategic judgement. To such a practitioner, this planning guide - which covers tax-planning considerations in depth for US companies doing business in the EU - should be of value. Starting from the proposition that holding company regimes are generally favourable in Europe - and poised to become more so as the Societas Europaea (SE) becomes established - Professor Dorfmueller analyzes the design of tax conversion and deferral structures that are advantageous to US multinationals as they pursue the following crucial objectives of tax planning. It covers: satisfying goals, such as minimizing liability, maximizing credits, deducting expenses and utilizing losses; using appropriate tools, such as routing of income and classification of entities; and overcoming barriers, especially those erected by the controlled foreign corporation (CFC) provisions of the US tax law known as "Subpart F". A detailed examination of how these methodologies are best pursued under US federal corporate law is complemented by an equally precise analysis of European company taxation, with specific tax planning techniques spelled out for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg and Switzerland. The reader should find many valuable suggestions on such specialised techniques as onshore pooling in the UK, gaining access to favourable Argentine taxation via a Spanish holding company, and the potential tax ramifications of EU enlargement.
(source: Nielsen Book Data)9789041199225 20160528
Law Library (Crown)
xxiii, 646 p. : ill., maps ; 24 cm.
Law Library (Crown)
xvi, 283 pages ; 25 cm.
  • Preface
  • Introduction
  • Tax treatment of inter-corporate cross-border dividends
  • Interaction among diferent legal systems of international tax law
  • Different dividend concepts in international tax law
  • Dividend-distribution entities
  • Dividend-stripping and the dividend-generating relationship
  • Fictive distributions as a dividend
  • Classification of economic benefits from corporations to their shareholders in the form of transfer prices
  • Classification of return on debt-equity hybrids
  • Classification of interest in thin capitalization situations
  • Classification of liquidation distributions
  • Concluding remarks.
"The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This...work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: payments made under dividend-stripping arrangements; fictitious profit distributions; economic benefits in the context of transfer pricing; returns on debt-equity hybrids; [and] interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states national tax law are covered by a more general analysis."-- Back cover.
Law Library (Crown)
2 volumes ; 25 cm
  • Key global tax concerns / Peter H. Blessing
  • Due diligence / Peter H. Blessing
  • Tax indemnities / Peter H. Blessing
  • European Union / James Smith, Andrew Stuart & Philip Thomas
  • Joint ventures / Peter H. Blessing
  • Business restructurings / Peter H. Blessing
  • Coroporate redomiciliations / Peter H. Blessing
  • Argentina / Gabriel Gotlib & Fernando M. Vaquero
  • Australia / Richard Hendriks & Richard Vann
  • Belgium / Werner Hevvaert
  • Brazil / Ricardo Luiz Becker & Flavio Veitzman
  • Canada / Robert Kopstein, Dan Jankovic, Soraya M. Jamal, Chris Van Loan, Sabrina Wong & Josh Jones
  • People's Republic of China / Stephen Nelson & Peng Tao
  • Finland / Janne Juusela & Sanna Lindqvist
  • France / Sophie Jouniaux & Benoit Menez
  • Germany / Stephan Eilers & Martin Schiessl
  • India / Shefali Goradia
  • Italy / Riccardo Michelutti & Alban Zaimaj
  • Japan / Takeo Mizutani & Eric N. Roose
  • Republic of Korea / Soo-Jeong Ahn, Jin Soo Soh & Jeong-mo Koo
  • Mexico / Jose Carlos Silva & Adalberto Valadez
  • The Netherlands / Margriet E. Lukkien & Monica Sada Garibay
  • Russian Federation / Victor Matchekhin
  • Spain / Sonia Velasco, Javier Asensio, Marti Adroer & Brigida Galbete
  • Sweden / Peter Utterstrom & Daniel Gustafsson
  • Switzerland / Daniel Bader, Daniel Lehmann, Peter Reinarz & Susannne Schreiber
  • United Kingdom / Dominic Stuttaford
  • United States / Peter H. Blessing & Ansgar A. Simon.
"[This book] is comprised of two complementary parts: first, a practical overview of certain key tax aspects of international transactions that have general application, followed by twenty-one...country profiles, pinpointing each jurisdiction's handling of such areas of concern as entity classification, taxable transactions, tax-free transactions (both domestically and cross-border), loss planning, IP planning, compensation arrangements, acquisition financing, JV planning, VAT issues, tax treaty usage, and much more. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. The work will assist in planning and evaluating strategies for transactions in single and multiple jurisdictions, as well as in implementing them. It further will allow a...comparison of key tax aspects in major jurisdictions."-- Provided by publisher.
Law Library (Crown)
xxx, 461 pages : illustrations ; 25 cm.
  • Introduction
  • Overview of international taxation
  • Examples of country tax systems
  • Manufacturing
  • Procurement companies
  • Distribution and regional sales companies
  • Shipping and air transport
  • Value added tax
  • Customs duties and tariffs
  • The digital economy
  • Social security taxes
  • Tax incentives
  • taxation issues for dividends and profit distributions
  • Taxation issues for funding and interest flows
  • Group restructures and taxation issues for capital gains
  • R&D and intellectual property
  • Treasury and in-house banking companies
  • Group insurance companies : captive insurance
  • Taxation issues for mergers and acquisitions
  • Acquisitions and sale and purchase agreements
  • Tax due diligence for mergers and acquisitions
  • Asset leasing
  • Derivatives : options, forwards and swaps
  • Interest deductions in subsidiaries and thin capitalism
  • Tax havens and controlled foreign corporations rules
  • Introduction to transfer pricing
  • Transfer pricing issues for manufacturing and distribution
  • Intangibles and transfer pricing
  • Intra-group services and transfer pricing
  • Loan financing, interest payments and transfer pricing
  • General Conclusions
  • Case studies
  • Appendices.
Law Library (Crown)
xxviii, 443 pages : illustrations ; 25 cm.
Law Library (Crown)
"The Transfer Pricing Forum is a new interactive bi-monthly online service bringing detailed practical guidance on technical Transfer Pricing issues. In the form of a practical and topical question, current Transfer Pricing topics are analyzed and discussed in detail by individual experts in over 20 countries. The Transfer Pricing Forum provides an instant comparison of different approaches to the same problem across jurisdictions. Countries covered include: Argentina, Austria, Australia, Belgium, Brazil, Canada, China, Denmark, France, Germany, Hong Kong, India, Italy, Ireland, Japan, Mexico, New Zealand, The Netherlands, Poland, Russia, Spain, Switzerland, United Kingdom, and the United States."
Law Library (Crown)
x, 565 p. : ill ; 23 cm.
  • Acknowledgments. Introduction. Taxes: Deal Making's Forgotten Value Driver. Financing and Hybrids: Maximizing Your Tax and Legal Structures. Country-by-Country Guide. Argentina. Australia. Austria. Belgium. Brazil. Canada. Chile. China. Czech Republic. Denmark. France. Germany. Hong Kong. Italy. Japan. Luxembourg. Malaysia. Mexico. Netherlands. New Zealand. Norway. Poland. Russia. Singapore. Slovak Republic. Spain. Sweden. Switzerland. Turkey. United Kingdom. United States.
  • (source: Nielsen Book Data)9780471653950 20160615
How you handle global tax issues can make or break a deal. Gain a better understanding of these issues with guidance from PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide When a business engages in a multinational merger or acquisition, dealing with a diverse set of transaction-related tax rules is one of the major challenges to successful implementation. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide helps you navigate the complexities unique to these international deals. This invaluable guide focuses on the global tax aspects of mergers and acquisitions to provide you with the information you need to move the deal forward-under a variety of circumstances and in numerous markets. Presenting individual chapters for each of thirty-one countries, this essential handbook provides quick access to the tax information you need, and, as much as possible, reduces the effort required to compare the rules that apply in one jurisdiction with the rules that apply in others. Each country-specific chapter includes an overview of the general approaches to mergers and acquisitions taxation issues as well as detailed information about how the tax authorities in each country apply the rules to various aspects of a transaction. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide offers tax planners a foundation of information that they need when involved in international mergers and acquisitions. It also covers many of the finer points of the broader tax issues that arise during planning and negotiation. Many will find this valuable reference to be an indispensable desktop tool in their effort to gain a deeper understanding of the global tax environment.
(source: Nielsen Book Data)9780471653950 20160615
SAL3 (off-campus storage)
560 p. ; 23 cm.
Green Library
571 p. : ill. ; 23 cm.
Law Library (Crown)

19. Taxation [2000]

ix, 98 p. : ill. ; 21 cm.
Law Library (Crown)
129 p. : ill. ; 23 cm.
Green Library


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