Basic international taxation /
Saved in:
| Author / Creator: | Rohatgi, Roy. |
|---|---|
| Imprint: | London ; New York : Kluwer Law International, c2002. |
| Description: | xiv, 704 p. ; 25 cm. |
| Language: | English |
| Subject: | |
| Format: | Print Book |
| URL for this record: | http://pi.lib.uchicago.edu/1001/cat/bib/4606712 |
Table of Contents:
- Sect. 1. 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
- Sect. 2. 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
- Sect. 3. 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
- Sect. 4. 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
- Sect. 5. 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
- Sect. 6. Anti-Avoidance Measures
- I. General
- II. Judicial anti-avoidance doctrines
- III. Anti-treaty shopping measures
- IV. Thin capitalisation
- V. Transfer pricing
- VI. Some other anti-avoidance measures
- VII. Anti-avoidance and international tax planning
- Sect. 7. 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
- Sect. 8. 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. International Tax Glossary
- 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).