Tax arbitrage : the trawling of the international tax system

著者

    • Feetham, Nigel

書誌事項

Tax arbitrage : the trawling of the international tax system

Nigel Feetham

Spiramus, 2011

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注記

Includes index

内容説明・目次

内容説明

International tax arbitrage has come under intense scrutiny since the global financial crisis, and is usually portrayed as a form of aggressive tax avoidance. Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice. In a world where tax competition rather than tax harmonisation is the predominant norm, international tax arbitrage is a form of legitimate tax planning. The book starts with a review of some of the press coverage (including of recent court cases) and also examines campaigns by the Uncut pressure group. It considers the confusion over the boundary between ""legality"" and ""morality"". It covers the responses of tax authorities in major western economies to calls for tax reform. This includes the choices to favour: Substance or form. Worldwide or source taxation. Targeted legislation or general anti-avoidance rules. It considers the role of jurisdictional competition in tax avoidance arbitrage and the approach taken by a number of countries (including the UK, Ireland and Netherlands) to fiscal policy. A review of recent law reports in the UK, Italy, France, New Zealand, Australia, United States and South Africa involving tax arbitrage, helps to explain how it works, with detailed descriptions from court cases and flow charts of the structured finance arrangements. The appendices include an extract from the OECD Report Building Transparent Tax Compliance by Banks on international arbitrage financing transactions, and the UK Code of Practice on Taxation for Banks with guidance notes.

目次

Introduction Summary of the book CHAPTER 1: The bail out - from hero to villain The media feeding frenzy Other side of the Atlantic US Senate "Tax Dodge" Report CHAPTER 2: Tax authorities intervention USA borrower Substance v Form Worldwide taxation and tax credits Securities Lending and Repo Taxpayers file lawsuits in the US claiming tax refunds US docketed cases Who owns the public transport system? CHAPTER 3: Structured finance The 'art' of tax avoidance Blowing the whistle Regulators and tax arbitrage When the herd moves in The spirit of the law GAAR Differing approaches Impact of European jurisprudence Are tax havens to blame? CHAPTER 4: The role of jurisdictional competition in tax avoidance arbitrage Uncut Going Dutch Consumer choice Entity classification for tax purposes Every taxpayer's dream (or not) When the taxman calleth CHAPTER 5: Jurisdictional case review THE UK ITALY FRANCE NEW ZEALAND AUSTRALIA UNITED STATES SOUTH AFRICA Concluding remarks Epilogue Appendix 1: Jurisdictional Arbitrage Financing Transaction Appendix 2: A Code of Practice on Taxation for Banks Appendix 3: Supplementary Guidance Note

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