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This superb book will guide the reader through the key issues and practical aspects of international tax practice. It demonstrates how different global tax systems interact and how to prevent paying more tax than necessary. The basic principles of each aspect of international taxation are outlined and then examined in greater depth and detail. This updated third edition includes coverage of both UK and EU legislation and regulation, as well as the key cases and rulings. Complicated double taxation concepts are clearly illustrated with examples and diagrams to help the reader quickly understand how they'll apply in practice. Examples of policies adopted in other countries are included, along with specialist commentary and guidance.
"Basic International Taxation provides a uniquely comprehensive overview of the basic principles of international taxation and considers these in the context of practical planning guidance. The analysis of the practical application of these principles is supported by a detailed review of current international tax practices by leading professionals in over sixty jurisdictions worldwide. "Volume I: Principles covers the basic principles of international taxation, an analysis of model tax treaties and a broad overview of various domestic tax systems. It also includes a glossary of terms and a copy of the OECD, UN and US model tax treaties.
This book highlights principles of international taxation based on recommendations of OECD and UN as contained in their Model Tax Conventions and pertaining commentaries. The book includes analysis, article by article, of all of India's 65 tax treaties. Tables in each chapter show, mostly in a condensed manner, the contents of every single article.Special feature of the book is extensive treatment of tax problems of the international industry of setting up plant, machinery and infrastructure and construction industry, based on the practical experience of the authors.
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
`Electronic commerce' -- a broad spectrum of commercial activities carried out through the use of computers -- has arrived. But tax authorities have questioned whether existing tax principles and rules are equipped to deal with the challenges of conducting business in cyberspace. Electronic Commerce and International Taxation examines the implications of the growth of electronic commerce for domestic and international tax systems, concentrating on the conduct of electronic commerce over the Internet. It covers a wide array of activities, focusing on basic rules and policy choices. The book looks at existing tax principles, how they might apply to hypothetical transactions involving electronic commerce, and possible alternative approaches. Coverage includes: the basic principles that govern income and value added taxesan overview of the technological changes that have brought about electronic commercea concise explanation of how and what happens when electronic commerce is conductedan examination of the ways in which businesses are using the new technology in conducting their everyday activitiesa discussion of the application of existing tax principles to electronic commercean exploration of questions and problems raised by applying tax rules that evolved before electronic commerce to transactions that were then unimaginableobservations and suggestions for a variety of approaches to international tax problems resulting from electronic commerce and the associated benefits and problems Because the implications of electronic commerce vary from industry to industry, this book focuses on the broad issues that span all industries. the information provided will keep tax attorneys, accountants, corporate counsel, policymakers, and academics in the field of tax law abreast of the issues posed by this hot topic and their many potential implications. This unique resource is an important part of becoming conversant in the language of a changing world.
Riahi-Belkaoui outlines a systematic approach that helps U.S. multinationals operating worldwide reduce their tax burden. Embedded in this approach are five issues crucial to planning a successful multinational tax strategy: an appreciation of the principles of taxation and the U.S. taxation of foreign income; the choice of a transfer pricing method; the use of tax vehicles for exporting, and the efficient use of value-added taxation. Riahi-Belkaoui explores each of these issues in a clear, concise manner. His book will be useful not only to professionals in international business and international tax experts, but also to their colleagues in the academic community.
Tax practitioners outside the United States whose clients have activities in the country generally rely on their U.S. tax advisors for technical advice on the U.S. tax aspects of their clients' transactions. In order to position themselves to evaluate the advice received and to relate it to their own tax systems, however, foreign tax advisors must place the material they receive from their U.S. counterparts within the overall structure of the U.S. international tax system. Introduction to United States International Taxation provides the structural framework within which a U.S. tax problem can be placed. Now in its fourth edition, this reliable resource presents the basic principles and rules of the U.S. international tax system in a concise, manageable form. Without becoming mired in technical detail, the book provides an overview of the principles adopted by the United States in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the United States or abroad. The inclusion of or reference to many key primary source documents enhances the usefulness of Introduction to United States International Taxation. These include: Internal Revenue Code provisions under discussion the more important Treasury Regulations issued interpreting the statutory rules significant administrative announcements of the Internal Revenue Service (Revenue Rulings and Revenue Procedures) illustrative principal cases
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