The international aspects of income taxation have become increasingly
important as countries worldwide have become more economically integrated.
International Tax Primer provides an introduction to the policies that
countries seek to advance with their international tax rules, with numerous
examples drawn from the practices of both developed and developing countries.
It grew out of the authors' work with the OECD in conducting seminars on
international tax for tax officials in countries emerging from the collapse of
the Soviet Union.
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
the role of the tax adviser;
tax planning techniques;
international double taxation;
transfer pricing; anti-avoidance rules;
tax treaties, including discussion of the OECD and UN Model Treaties;
emerging issues, such as e-commerce and harmful tax competition.
Preface Chapter 1. Introduction A. Objectives of this Primer B.
What is International Tax? C. Goals of International Tax Rules D.
The Role of the Tax Adviser in Planning International Transactions Chapter
2. Jurisdiction to Tax A. Introduction B. Defining Residence C.
Source Jurisdiction Chapter 3. Double Taxation Relief A. Introduction
B. International Double Taxation Defined C. Relief Mechanisms D.
Allocation of Expenses E. Tax Sparing Chapter 4. Transfer Pricing A.
Introduction B. Arm’s Length Method C. Determining the
Income of a Branch or Permanent Establishment of a Corporation D.
Formulary Apportionment and the Future of the Arm’s Length Method
Chapter 5. Anti-Avoidance Measures A. Introduction B. Thin
Capitalization Rules C. Controlled Foreign Corporation (CFC) Rules D.
Offshore Investment Funds Chapter 6. Tax Treaties A. Overview B.
Contents of a Typical Tax Treaty C. Special Treaty Issues Chapter
7. Emerging Issues A. Harmful Tax Competition B. Hybrid Entities
C. Electronic Commerce Glossary of International Tax Terms, Selected