Principles of international taxationPDF电子书下载
- 电子书积分:13 积分如何计算积分?
- 作 者:by Angharad Miller and Lynne Oats.
- 出 版 社:
- 出版年份:2006
- ISBN:1845923273;1845923278
- 页数:359 页
Part 1 Introduction to Tax 1
1 Introduction to Taxation 3
Why governments levy taxes 3
Elements of taxes 4
Types of taxes 5
The flat tax debate 10
Compliance and administrative costs of taxation 11
Tax avoidance 12
Tax expenditures 12
Evaluating taxes and tax systems 13
Comparative taxation 14
Summary 14
Further reading 14
Part 2 Introduction to International Tax Chapter 17
2 Introduction to International Taxation 19
Introduction 19
Further reading 26
3 The Right to Tax Individuals 28
Introduction 28
The UK’s approach to determining the tax residence of individuals 31
The concept of domicile 39
Summary 41
References 42
4 The Right to Tax Companies 44
Introduction 44
Further reading 56
5 The Double Tax Problem 57
Introduction 57
The basic problem 57
Double tax relief 58
Types of foreign tax which may qualify for double tax relief 67
Withholding taxes 68
Summary 71
Further reading 72
6 Variations on the Credit Method 73
Introduction 73
The UK’s double tax relief regime 75
Case study: London plc 75
The UK system prior to FA 2000 - strict source by source 77
The system prior to FA 2000 - offshore pooling 78
The link with anti-haven legislation 78
London plc: offshore pooling without restrictions 79
The double tax relief system in the UK post FA 2000 -limited onshore pooling 82
Application of onshore pooling to London plc 83
The elimination of the advantages of offshore pooling 86
London plc: onshore pooling where an offshore intermediate holding company is used 87
Future developments in UK double tax relief 90
Summary 90
Further reading 91
7 Double Tax Treaties 92
Introduction 92
The relationship of tax treaties to domestic law 93
The development of tax treaties 94
The OECD Model Convention of 1963 (revised 1977 and 1992) 95
Allocating the right to tax between the two contracting states 98
Main articles in the OECD Model Convention 99
Tax sparing 107
Limitation of benefits clauses 108
Interpretation of tax treaties 108
Limitations on the use of double tax treaties by tax authorities 109
The use of multilateral treaties 109
Summary 110
Further reading 110
Part 3 International Tax Planning 113
8 Permanent Establishments 115
Introduction 115
The concept of a permanent establishment 115
A ‘fixed place of business’ 117
The use of agents 121
Fellow group companies as PEs 126
The UK domestic law on PE 126
The attribution of profits to a PE 127
PE - an outdated concept? 129
Summary 130
Further reading 131
9 Companies Expanding Abroad 133
Introduction 133
Inward investment into the UK 134
Outward investment by a UK company 136
The impact of tax-sparing provisions 141
Summary 143
Further reading 144
10 Individuals Working Abroad 145
Introduction 145
Tax position of UK residents working abroad 145
Tax allowances 147
Tax position of individuals coming to the UK to work 147
Tax treatment of employees resident but not ordinarily resident in the UK 149
Tax treatment of employees who have a foreign domicile and work for a non-resident employer 150
Travelling expenses 153
Special deduction for seafarers 154
National Insurance contributions for employees going to work abroad 154
The taxation of share options for internationally mobile employees 155
Tax equalisation arrangements 155
Personal tax planning for employees posted abroad 156
Summary 157
Further reading 157
11 Tax Aspects of Financing for Multinational Groups 159
Introduction 159
The effect of withholding taxes 160
International treasury management within multinational groups of companies 162
Maximising the value of the tax deduction for interest:basic strategies 163
Financing investment in countries with high inflation 166
Cross-border tax arbitrage 166
Summary 169
Further reading 170
Part 4 International Tax Avoidance 171
12 Introduction to Tax Havens 173
Introduction 173
Rationale for the use of tax havens 173
The growth of the offshore financial sector 177
Summary 186
Further reading 186
13 Anti-Haven Legislation 188
Introduction 188
The five possible grounds for exemption 196
Captive insurance companies 202
Summary 203
Further reading 204
14 Transfer Pricing 205
Introduction 205
The ‘arm’s-length’ principle 208
A very brief history of transfer pricing legislation 209
The role of the OECD 210
Recommendations in the 1994 OECD guidelines 211
Transaction based methods of determining arm’s-length prices 215
Transactional profits based methods 221
Other profit based methods 225
Cost sharing arrangements 225
The UK transfer pricing legislation - ICTA 1988, Sch 28AA 228
Industry focus - the pharmaceutical industry 229
Transfer pricing and financial transactions 231
Record keeping 238
Penalties 239
Advance Pricing Agreements (APAs) 239
The risk of double taxation from transfer pricing adjustments 240
Is the OECD right in insisting on the arm’s-length principle? 242
Alternative to arm’s length - formulary apportionment 243
Summary 244
Further reading 246
15 Treaty Shopping 249
Introduction 249
Forms of treaty shopping 249
Common law and treaty shopping 253
Tax treaties and treaty shopping 254
The UK-US Treaty 257
Summary 258
Further reading 259
Part 5 International Tax Policy 261
16 E-Commerce 263
Introduction 263
PEs: the questions posed by global e-commerce 264
Can an automated machine be a ‘PE’? 265
Dangers of substantially altering the ‘PE’ rule 267
Proposals evaluated by the TAG in the November 2003 discussion draft 267
The current UK position on electronic commerce 268
The impact of the current OECD proposals for attribution of profits to PEs on the taxation of electronic commerce 269
Electronic commerce and transfer pricing 269
Summary 270
Further reading 270
17 Tax Competition 272
Introduction 272
Competition with regard to portfolio investment 273
Tax competition - direct investment 273
Use of foreign company/branch for group treasury and finance operations 274
The EU Code of Conduct 276
The OECD initiative on Harmful Tax Competition 278
Removing tax competition - the case of the Belgian Coordination Centres 281
The arguments for retaining tax competition 284
Further reading 285
18 European Corporation Tax Issues 287
Introduction 287
EU principles affecting tax issues 287
Moves towards harmonisation already in place: the Directives 289
Current EU proposals for harmonisation of direct taxation 292
The common consolidated EU corporate tax base 299
The European Corporate Income Tax (EUCIT) 303
Societas Europaea - the European Company 304
Harmonisation and the accession States - the flat tax obstacle 305
Recent and important cases 305
Summary 313
Further reading 313
19 VAT and Customs Duties 315
How VAT works 315
Alternative systems for dealing with cross-border supplies 317
Imports to and exports from the EC 320
Cross-border supplies of goods within the EC 323
Supplies of services 326
Beyond the Transitional Regime - the ‘Definitive System’ 331
Summary 337
Further reading 341
Index 343
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