Principles of international taxation
著者
書誌事項
Principles of international taxation
（Basic international taxation / Roy Rohatgi, vol. 1）
Richmond Law & Tax , BNA International, c2005
2nd ed
- Richmond : hbk
- Richmond : pbk
- BNA : hbk
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注記
Includes bibliographical references and index
内容説明・目次
内容説明
"Basic International Taxation" provides a uniquely comprehensive overview of the basic principles of international taxation and considers these in the context of practical planning guidance. The analysis of the practical application of these principles is supported by a detailed review of current international tax practices by leading professionals in over sixty jurisdictions worldwide. "Volume I: Principles" covers the basic principles of international taxation, an analysis of model tax treaties and a broad overview of various domestic tax systems. It also includes a glossary of terms and a copy of the OECD, UN and US model tax treaties. This volume is an introductory one and sets the scene for "Volume II: Practice". The second volume includes practical guidance on international tax planning techniques, the use of offshore financial centres for international tax planning, a brief country tax profile of over sixty countries, an analysis of anti-avoidance rules and an overview of some of the current issues in international taxation.
目次
- VOLUME I
- PREFACE
- ABOUT THE AUTHOR
- I AN OVERVIEW OF INTERNATIONAL TAXATION
- 1. Objectives of Global Tax Systems
- 2. International Tax Conflicts and Double Taxation
- 3. Double Tax Treaties
- 4. Domestic Tax Systems
- 5. International Offshore Financial Centres
- 6. Anti-avoidance Measures
- 7. International Tax Planning
- 8. Structure of the Book
- 9. Suggested Further Reading
- II PRINCIPLES OF INTERNATIONAL TAX LAW
- 1. International tax law
- 2. Interpretation of Tax Treaties
- 3. Some legal Decisions on Treaty Interpretations
- 4. Applicability of Tax Treaties
- 5. Model Tax Convention
- 6. Multilateral Tax Agreements
- 7. European Union
- 8. Suggested Further Reading
- III MODEL TAX CONVENTIONS ON DOUBLE TAX AVOIDANCE
- 1. OECD Model Convention ("OECD MC")
- 2. UN Model Convention ("UN MC")
- 3. US Model Convention ("US MC")
- 4. Articles in Model Conventions
- 5. Bilateral Tax Treaties
- 6. Suggested Further Reading
- IV IMPACT OF DOMESTIC TAX SYSTEMS
- 1. Introduction
- 2. Tax Residence or Fiscal Domicile
- 3. Source of Income or Gain
- 4. Basis of Tax Computation
- 5. Treatment of Tax Losses
- 6. Tax Consolidation Rules ("Group Taxation")
- 7. Passive Income
- 8. Foreign Tax Relief
- 9. Suggested Further Reading
- INTERNATIONAL TAX GLOSSARY
- EXHIBITS - MODEL TAX TREATIES
- 1. OECD Model Tax Convention on Income and on Capital (January 28, 2003)
- 2. United Nations Model Tax Convention Between Developed and Developing Countries (January 11, 2001)
- 3. United States Model Income Tax Convention (September 20, 1996)
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