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Pris: 2215 SEK exkl. moms  |  International Taxation of Banking introduces and analyses the international tax issues which relate to international banking activities. Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups.
What’s in this book:
The content of this book clearly identifies and explains the management of research and development and intangible property used in the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book examines such issues as the following:
- taxation of dividends and branch profits derived from other countries;
- transfer pricing and branch profit attribution;
- taxation of global trading activities;
- tax risk management;
- provision of services and intangible property within multinational groups;
- taxation treatment of research and development expenses;
- availability of tax incentives such as patent box tax regimes;
- swaps and other derivatives;
- loan provisions and debt restructuring;
- financial technology (FinTech);
- group treasury, interest flows, and thin capitalisation;
- tax havens and controlled foreign companies; and
- taxation policy developments and trends.
Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail.
How this will help you:
The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will serve as an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Contents:
Preface
List of Abbreviations
CHAPTER 1. Introduction
CHAPTER 2. The Banking Regulatory Framework
CHAPTER 3. Retail and Commercial Banking
CHAPTER 4. Investment Banking
CHAPTER 5. Introduction to International Tax
CHAPTER 6. Tax Treaties
CHAPTER 7. OECD BEPS Developments
CHAPTER 8. Bank Parent Companies
CHAPTER 9. Bank Branches
CHAPTER 10. Other Bank Permanent Establishments
CHAPTER 11. Representative Offices
CHAPTER 12. Derivatives
CHAPTER 13. Loan Provisions and Debt Restructuring
CHAPTER 14. Value Added Tax: VAT
CHAPTER 15. Bank Taxes: Financial Transaction Taxes and Bank Levies
CHAPTER 16. Dividends and Profit Distributions
CHAPTER 17. Group Treasury, Interest Flows and Thin Capitalisation
CHAPTER 18. Intangible Property: IP
CHAPTER 19. Tax Havens and Controlled Foreign Companies: CFCs
CHAPTER 20. Introduction to Transfer Pricing
CHAPTER 21. Transfer Pricing and Bank Branch Attribution
CHAPTER 22. Transfer Pricing and Global Trading
CHAPTER 23. Transfer Pricing and Loans
CHAPTER 24. Transfer Pricing and Intangibles
CHAPTER 25. Transfer Pricing and Services
CHAPTER 26. Islamic Banking
CHAPTER 27. Green Banking
CHAPTER 28. Microfinance Banking
CHAPTER 29. Financial Technology: Fintech
CHAPTER 30. Shadow Banking
CHAPTER 31. Automatic Exchange of Information: CRS and FATCA
CHAPTER 32. Taxation Policy Developments
CHAPTER 33. General Conclusions
Case Studies
Case Study 1. The Malaysia Branch: Permanent Establishments and Treaties
Case Study 2. The Korean Bank Acquisition: Group Interest Deductions
Case Study 3. Group Technology: Global Risk Management Cloud Software and Tax Treaties
Case Study 4. The Italian Branch: Branch Attribution
Case Study 5. Branch Profit Attribution: Corporate Loans and Global Trading
Case Study 6. The Group Advertising Centre: Transfer Pricing Dispute
Appendix.
OECD Model Tax Convention 2017
Table of Cases
Table of Statutes and Directives
Table of Treaties and International Agreements
Index | | |
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