Pub. Date:
Wolters Kluwer Law & Business
International Tax Primer / Edition 4

International Tax Primer / Edition 4

by Brian J. ArnoldBrian J. Arnold


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About this book:

International Tax Primer provides an accessible and comprehensive guide to the fundamental aspects of international taxation with an introduction to the policies that countries seek to advance with their international tax rules. Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive and continuing issues concerning the digital economy.

What’s in this book:

The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following with an extensive glossary of international tax terms:

  • role of the tax adviser in planning international transactions;
  • taxation of residents on foreign income and of nonresidents on domestic income;
  • mechanisms used to mitigate the risks to taxpayers of international double taxation;
  • transfer pricing rules to prevent the avoidance of tax by multinational corporations;
  • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities;
  • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and
  • challenges posed by taxation of income derived from the digital economy.

How this will help you:

With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis. The Primer provides the reader an easy-to-read understanding of the basic concepts and structural features of international taxation that form the basis for all countries’ international tax rules obtaining an understanding of the tax policy principles underlying the international tax system.

Product Details

ISBN-13: 9789403502823
Publisher: Wolters Kluwer Law & Business
Publication date: 01/15/2019
Edition description: 4th ed.
Pages: 264
Sales rank: 997,851
Product dimensions: 6.30(w) x 9.80(h) x 0.80(d)

Table of Contents

Preface. 1: Introduction. A. Objectives of this Primer. B. What is International Tax? C. Goals of International Tax Rules. D. Role of the International Tax Adviser. 2: Jurisdiction to Tax. A. Introduction. B. Defining Residence. C. Source Jurisdiction. 3: Double Taxation Relief. A. Introduction. B. International Double Taxation Defined. C. Relief Mechanisms. D. Allocation of Expenses. E. Tax Sparing. 4: Transfer Pricing. A. Introduction. B. Arm's Length Method. C. Treaty Aspects of Transfer Pricing. D. Future of the Arm's Length Method. 5: Anti-Avoidance Measures. A. Introduction. B. Thin Capitalization Rules. C. Controlled Foreign Corporation (CFC) Rules. D. Offshore Investment Funds. 6: Tax Treaties. A. Overview. B. Contents of a Typical Tax Treaty. C. Special Treaty Issues. Glossary of International Tax Terms. Selected Bibliography. Index.

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