About Product
This book represents a different approach to Principles of International Tax Planning. It takes a departure from the widely held view that international taxation must be approached from a domestic perspective. With the emergence of services and digital economies, pushed by technological advancements, international tax is now prominent in the considerations of business around the world. The issues, techniques and disciplines are quite different from domestic tax considerations, and the aim of this book is to demonstrate and help the reader understand the intricacies of international tax planning. Based around a case study of a fictitious Italian family with an abundance of person and corporate tax issues, the work is presented in four parts, each covering a specific issue of international tax planning. The first section analyses the laws applicable to the issue in question, and the last section of each Part puts this into context by reference to the case study. The Present Publication, authored by Roy Saunders, is the latest edition, with the following contents: Part One – Sources o Chapter 1: Will a foreign tax liability arise if one has a foreign source of income or capital? § Source § Types of Income § Withholding Tax o Chapter 2: Is it possible to reduce a foreign tax liability through treaty or other arrangements? § Functions of Double Tax Treaties § Parties to Double Tax Treaties § Arrangement of the OECD Model Treaty § EU Directives Part Two – Residence o Chapter 3: Will one have to pay domestic tax on overseas sources of income or capital because of one’s residence, even if one does not remit the income or capital? § Entity Classification and General Tax Characteristics § Residence, Domicile and Citizenship § Worldwide v. Territorial Principles of Taxation § Considerations on Transferring Residence to Another Country o Chapter 4: Is it possible to reduce one’s domestic taxation liability by using foreign entities? § Withholding Companies § Offshore Trusts § Foundations § Life Assurance Policies Part Three – Indirect Taxes o Chapter 5: Have you considered the impact of indirect taxes on income and capital? § Value Added Taxes § Other Sales Tax § Customs Duties § Capital Taxes Part Four – Tax Avoidance o Chapter 6: Would the advice stand up to scrutiny? § Tax Mitigation, Tax Avoidance and Tax Evasion § Sham Transactions § Substance over Form § General Anti-Avoidance Rules (GAAR) § Use of Law-Tax Jurisdictions o Chapter 7: Do the entities involved in a structure have substance? § Beneficial Ownership Concept § Conduit Companies § CFC Legislation Related to Passive Activities of Subsidiary Companies § Anti-Avoidance Provisions in Respect of Transfer of Assets Abroad § Accessing Offshore Funds & Tax Amnesties o Chapter 8: Are transactions carried out at arm’s length? § Transfer Pricing § Thin Capitalisation § Fundamental Consideration in Determining Allowable Expenses § Constructive Dividends
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Taxation;
