 Contents:
Chapter 5: Basic Principles of International Tax Planning
International Tax Planning
International Tax Structures
Tax Planning for Cross-border Transactions -- Some Examples
International Tax Planning for Expatriate Individuals
Avoidance of Economic Double Taxation of Dividends
Tax Consolidation Rules ("Group Taxation")
Suggested Further Reading
Chapter 6: Anti-Avoidance Measures
General
Judicial Anti-avoidance Doctrines
Anti-treaty Shopping Measures
Controlled Foreign Corporation
Thin Capitalisation
Transfer Pricing
Some Other Anti-avoidance Measures
Anti-avoidance and International Tax Planning
Suggested Further Reading
Chapter 7: International Offshore Financial Centres
General
What is a Tax Haven
The Role of Offshore Financial Centres
How to Choose an International Offshore Financial Centre
Examples of Intermediary Entities
Major Financial Centres
Current Issues and Developments
Suggested Further Reading
Chapter 8: Some Current Issues in International Taxation
Electronic Commerce
Cross-border Computer Software Payments
Technical Services and Assistance
Attribution of Income to Permanent Establishments
Treatment of Exchange Gains and Losses
Triangular Cases
Partnerships
Financial Instruments
Trusts
Employee Stock Options
Treaty Issues under the United Nations Model
Other Selected Topics
Suggested Further Reading
Chapter 9: National Tax Systems (Selected Countries)
Developed Economies
Developing Economies
Suggested Further Reading
Recent Developments in International Taxation
Exhibits - Model Tax Treaties
OECD Model Tax Convention on Income and on Capital (January 28, 2003)
United Nations Model Tax Convention between Developed and Developing Countries (January 11, 2001)
United States Model Income Tax Convention (September 20, 1996)
League of Nations Draft Treaties 1928 - 1946
Andean Model
Index to Volume Two |
