International Company Taxation and Tax Planning

The massive and growing increase in international trade and investment make it increasingly important for corporate counsel and tax practitioners to understand the complexity of tax systems worldwide and to plan for optimal specific arrangements in each cross-border business operation. International tax planning stands to be enormously enhanced by the kind of analysis presented in this one-of-a-kind book, combining as it does detailed information on tax law in scores of jurisdictions and practical guidance on international tax planning approaches.

The book represents the work of a team including both tax practitioners and academics, under the editorship of an academic in international taxation and a leading international tax consultant. It facilitates the understanding of international tax issues and provides specific guidance in such facets of international taxation as the following:

• sources of tax legislation;
• role of bilateral tax treaties;
• determination of taxable income;
• tax collection, enforcement, and compliance;
• elimination of double taxation;
• treatment of losses;
• pass-through taxation vs. separate entity approach;
• tax burden at the corporate and shareholder levels;
• inheritance tax;
• harmonized VAT in the EU;
• allocation of functions, risks, assets, and capital;
• target variables for international tax burden comparisons;
• cross-border leasing;
• tax structuring for mergers and acquisition;
• tax management of intellectual property; and
• the proposed EU Common Consolidated Corporate Tax Base (CCCTB).

In addition to frequent references to country-specific tax legislation including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere the book discusses important ECJ decisions and numerous other case studies. With its in-depth description, analysis, practical guidance, and new perspectives regarding questions of international tax planning, this book will be welcomed by practitioners engaged in the field of international taxation, whether they work in companies, law firms, or government. Interested academics will find here an unmatched comparative analysis of the global web of international taxation law and practice.