International Company Taxation

International Company Taxation

Author: Ulrich Schreiber

Publisher: Springer Science & Business Media

Published: 2013-01-30

Total Pages: 179

ISBN-13: 3642363067

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The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.


Book Synopsis International Company Taxation by : Ulrich Schreiber

Download or read book International Company Taxation written by Ulrich Schreiber and published by Springer Science & Business Media. This book was released on 2013-01-30 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

Introduction to United States International Taxation

Introduction to United States International Taxation

Author: Paul R. McDaniel

Publisher:

Published: 2014

Total Pages: 0

ISBN-13: 9789041136565

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This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. It sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad.


Book Synopsis Introduction to United States International Taxation by : Paul R. McDaniel

Download or read book Introduction to United States International Taxation written by Paul R. McDaniel and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. It sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad.

International Business Taxation

International Business Taxation

Author: Sol Picciotto

Publisher: Praeger

Published: 1992-03-02

Total Pages: 424

ISBN-13:

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This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.


Book Synopsis International Business Taxation by : Sol Picciotto

Download or read book International Business Taxation written by Sol Picciotto and published by Praeger. This book was released on 1992-03-02 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

Taxing Profit in a Global Economy

Taxing Profit in a Global Economy

Author: Michael P. Devereux

Publisher: Oxford University Press

Published: 2020-09-29

Total Pages: 401

ISBN-13: 0198808062

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The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.


Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux

Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.

International Company Taxation and Tax Planning

International Company Taxation and Tax Planning

Author: Dieter Endres

Publisher:

Published: 2015

Total Pages: 0

ISBN-13: 9789041145567

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This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.


Book Synopsis International Company Taxation and Tax Planning by : Dieter Endres

Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

International Taxation Handbook

International Taxation Handbook

Author: Colin Read

Publisher: Elsevier

Published: 2007-04-13

Total Pages: 391

ISBN-13: 0750683716

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Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.


Book Synopsis International Taxation Handbook by : Colin Read

Download or read book International Taxation Handbook written by Colin Read and published by Elsevier. This book was released on 2007-04-13 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.

International Taxation in an Integrated World

International Taxation in an Integrated World

Author: Jacob A. Frenkel

Publisher: MIT Press

Published: 1991

Total Pages: 268

ISBN-13: 9780262061438

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In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy.


Book Synopsis International Taxation in an Integrated World by : Jacob A. Frenkel

Download or read book International Taxation in an Integrated World written by Jacob A. Frenkel and published by MIT Press. This book was released on 1991 with total page 268 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy.

Principles of International Taxation

Principles of International Taxation

Author: Lynne Oats

Publisher: Bloomsbury Publishing

Published: 2021-09-30

Total Pages: 773

ISBN-13: 1526519569

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The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.


Book Synopsis Principles of International Taxation by : Lynne Oats

Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 773 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.

International Taxation of Banking

International Taxation of Banking

Author: John Abrahamson

Publisher: Kluwer Law International B.V.

Published: 2020-02-20

Total Pages: 448

ISBN-13: 9403510951

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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. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope 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. 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 prove to be 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.


Book Synopsis International Taxation of Banking by : John Abrahamson

Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope 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. 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 prove to be 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.

International Taxation

International Taxation

Author: Philip F. Postlewaite

Publisher:

Published: 2010

Total Pages: 0

ISBN-13: 9781594607974

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This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.


Book Synopsis International Taxation by : Philip F. Postlewaite

Download or read book International Taxation written by Philip F. Postlewaite and published by . This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.