 Summary of Contents:
- Sources of international tax law, such as domestic and international legislation in this area.
- Building blocks of international tax planning: arm’s length principle and permanent establishment.
- The differences between the concepts of tax planning, avoidance and evasion.
- Categorization of planning techniques based on their underlying principles
- The structure and goals of a multinational group, with particular emphasis on taxation.
- Tax planning techniques that can be used to effectively carry out activities such as holding, financing, hedging and IP management.
- Supply-chain management techniques and how taxes come into play when (re-)organizing them
- General and specific anti-avoidance rules that have from time to time been designed by States in order to counteract behaviours and structures that are not considered acceptable from a tax policy point of view. |
