Principles of international taxation2025|PDF|Epub|mobi|kindle电子书版本百度云盘下载

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Part 1 Introduction to Tax1

1 Introduction to Taxation3

Why governments levy taxes3

Elements of taxes4

Types of taxes5

The flat tax debate10

Compliance and administrative costs of taxation11

Tax avoidance12

Tax expenditures12

Evaluating taxes and tax systems13

Comparative taxation14

Summary14

Further reading14

Part 2 Introduction to International Tax Chapter17

2 Introduction to International Taxation19

Introduction19

Further reading26

3 The Right to Tax Individuals28

Introduction28

The UK’s approach to determining the tax residence of individuals31

The concept of domicile39

Summary41

References42

4 The Right to Tax Companies44

Introduction44

Further reading56

5 The Double Tax Problem57

Introduction57

The basic problem57

Double tax relief58

Types of foreign tax which may qualify for double tax relief67

Withholding taxes68

Summary71

Further reading72

6 Variations on the Credit Method73

Introduction73

The UK’s double tax relief regime75

Case study: London plc75

The UK system prior to FA 2000 - strict source by source77

The system prior to FA 2000 - offshore pooling78

The link with anti-haven legislation78

London plc: offshore pooling without restrictions79

The double tax relief system in the UK post FA 2000 -limited onshore pooling82

Application of onshore pooling to London plc83

The elimination of the advantages of offshore pooling86

London plc: onshore pooling where an offshore intermediate holding company is used87

Future developments in UK double tax relief90

Summary90

Further reading91

7 Double Tax Treaties92

Introduction92

The relationship of tax treaties to domestic law93

The development of tax treaties94

The OECD Model Convention of 1963 （revised 1977 and 1992）95

Allocating the right to tax between the two contracting states98

Main articles in the OECD Model Convention99

Tax sparing107

Limitation of benefits clauses108

Interpretation of tax treaties108

Limitations on the use of double tax treaties by tax authorities109

The use of multilateral treaties109

Summary110

Further reading110

Part 3 International Tax Planning113

8 Permanent Establishments115

Introduction115

The concept of a permanent establishment115

A ‘fixed place of business’117

The use of agents121

Fellow group companies as PEs126

The UK domestic law on PE126

The attribution of profits to a PE127

PE - an outdated concept?129

Summary130

Further reading131

9 Companies Expanding Abroad133

Introduction133

Inward investment into the UK134

Outward investment by a UK company136

The impact of tax-sparing provisions141

Summary143

Further reading144

10 Individuals Working Abroad145

Introduction145

Tax position of UK residents working abroad145

Tax allowances147

Tax position of individuals coming to the UK to work147

Tax treatment of employees resident but not ordinarily resident in the UK149

Tax treatment of employees who have a foreign domicile and work for a non-resident employer150

Travelling expenses153

Special deduction for seafarers154

National Insurance contributions for employees going to work abroad154

The taxation of share options for internationally mobile employees155

Tax equalisation arrangements155

Personal tax planning for employees posted abroad156

Summary157

Further reading157

11 Tax Aspects of Financing for Multinational Groups159

Introduction159

The effect of withholding taxes160

International treasury management within multinational groups of companies162

Maximising the value of the tax deduction for interest:basic strategies163

Financing investment in countries with high inflation166

Cross-border tax arbitrage166

Summary169

Further reading170

Part 4 International Tax Avoidance171

12 Introduction to Tax Havens173

Introduction173

Rationale for the use of tax havens173

The growth of the offshore financial sector177

Summary186

Further reading186

13 Anti-Haven Legislation188

Introduction188

The five possible grounds for exemption196

Captive insurance companies202

Summary203

Further reading204

14 Transfer Pricing205

Introduction205

The ‘arm’s-length’ principle208

A very brief history of transfer pricing legislation209

The role of the OECD210

Recommendations in the 1994 OECD guidelines211

Transaction based methods of determining arm’s-length prices215

Transactional profits based methods221

Other profit based methods225

Cost sharing arrangements225

The UK transfer pricing legislation - ICTA 1988, Sch 28AA228

Industry focus - the pharmaceutical industry229

Transfer pricing and financial transactions231

Record keeping238

Penalties239

Advance Pricing Agreements （APAs）239

The risk of double taxation from transfer pricing adjustments240

Is the OECD right in insisting on the arm’s-length principle?242

Alternative to arm’s length - formulary apportionment243

Summary244

Further reading246

15 Treaty Shopping249

Introduction249

Forms of treaty shopping249

Common law and treaty shopping253

Tax treaties and treaty shopping254

The UK-US Treaty257

Summary258

Further reading259

Part 5 International Tax Policy261

16 E-Commerce263

Introduction263

PEs: the questions posed by global e-commerce264

Can an automated machine be a ‘PE’?265

Dangers of substantially altering the ‘PE’ rule267

Proposals evaluated by the TAG in the November 2003 discussion draft267

The current UK position on electronic commerce268

The impact of the current OECD proposals for attribution of profits to PEs on the taxation of electronic commerce269

Electronic commerce and transfer pricing269

Summary270

Further reading270

17 Tax Competition272

Introduction272

Competition with regard to portfolio investment273

Tax competition - direct investment273

Use of foreign company/branch for group treasury and finance operations274

The EU Code of Conduct276

The OECD initiative on Harmful Tax Competition278

Removing tax competition - the case of the Belgian Coordination Centres281

The arguments for retaining tax competition284

Further reading285

18 European Corporation Tax Issues287

Introduction287

EU principles affecting tax issues287

Moves towards harmonisation already in place: the Directives289

Current EU proposals for harmonisation of direct taxation292

The common consolidated EU corporate tax base299

The European Corporate Income Tax （EUCIT）303

Societas Europaea - the European Company304

Harmonisation and the accession States - the flat tax obstacle305

Recent and important cases305

Summary313

Further reading313

19 VAT and Customs Duties315

How VAT works315

Alternative systems for dealing with cross-border supplies317

Imports to and exports from the EC320

Cross-border supplies of goods within the EC323

Supplies of services326

Beyond the Transitional Regime - the ‘Definitive System’331

Summary337

Further reading341

Index343