Basic International Taxation

Abstract

Section One: An Overview of International Taxation. I. Objectives of global tax systems. II. International tax conflicts and double taxation. III. Double tax treaties. IV. Domestic tax systems. V. International offshore financial centres. VI. Anti-avoidance measures. VII. International tax planning. VIII. Structure of the book. IX. Suggested further reading. Section Two: Principles of International Tax Law. I. International tax law. II. Interpretation of tax treaties. III. Some legal decisions on treaty interpretations. IV. Applicability of tax treaties. V. Model Tax Conventions. VI. Multilateral tax agreements. VII. Suggested further reading. Section Three: Model Tax Conventions on Double Tax Avoidance. I. OECD Model Convention on Income and Capital. II. UN Model Convention. III. US Model Convention. IV. Articles in Model Conventions. V. Bilateral tax treaties. VI. Suggested further reading. Section Four: Impact of Domestic Tax Systems. I. Introduction. II. Tax residence or fiscal domicile. III. Source of income or gain. IV. Basis of tax computation. V. Treatment of tax losses. VI. Tax consolidation rules (`group taxation'). VII. Passive income. VIII. Foreign tax relief. IX. Suggested further reading. Section Five: International Offshore Financial Centres (`IOFC'). I. General. II. What is a tax haven. III. The role of offshore financial centres. IV. How to choose an International Offshore Financial Centre. V. Examples of intermediary entities. VI. Major offshore financial centres. VII. Current issues and developments in the use of offshore financial centres. VIII. Suggested further reading. Section Six: Anti-Avoidance Measures. I. General. II. Judicial anti-avoidance doctrines. III. Anti-treaty shopping measures. V. Thin capitalisation. VI. Transfer pricing. VII. Some other anti-avoidance measures. VIII. Anti-avoidance and international tax planning. IX. Suggested further reading. Section Seven: Basic Principles of International Tax Planning. I. International tax planning. II. International tax structures. III. Tax planning for cross-border transactions - some examples. IV. International tax planning for expatriate individuals. V. Avoidance of economic double taxation of dividends. VI. Advance tax rulings. VII. Suggested further reading. Section Eight: Some Current Issues in International Taxation. I. Electronic commerce. II. Cross-border computer software payments. III. Technical services and assistance. IV. Attribution of income to permanent establishments. V. Treatment of exchange gains and losses. VI. Triangular cases. VII. Partnerships. VIII. Financial instruments. IX. Harmful tax competition. X. Suggested further reading. Section Nine: International Tax Glossary. Exhibits: Model Tax Treaties. OECD Model Tax Convention on Income and Capital (April 29, 2000). United Nations Model Tax Convention (1980). United States Model Income Tax Convention (September 20, 1996). Index.

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