Advanced introduction to international tax law
著者
書誌事項
Advanced introduction to international tax law
(Elgar advanced introductions)
Edward Elgar, c2019
2nd ed
- : pbk
- : cased
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注記
Includes bibliographical references (p. 148-158) and index
内容説明・目次
内容説明
Elgar Advanced Introductions are stimulating and thoughtful introductions to major fields in the social sciences and law, expertly written by the world's leading scholars. Designed to be accessible yet rigorous, they offer concise and lucid surveys of the substantive and policy issues associated with discrete subject areas.
This second edition of the Advanced Introduction to International Tax Law provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax.
This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.
New to this edition:
New material on the OECD Base Erosion and Profit Shifting (BEPS) project
Coverage of the EU's Anti Tax Avoidance Package
Analysis of the US Tax Cuts and Jobs Act
Key features include:
defines and discusses the main types of jurisdiction to tax
explains in depth both inbound and outbound taxation on both passive and active income
delineates the source of income that is crucial for taxing non-residents and foreign tax credit
discussion of transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source
explains how the above elements are influenced by tax treaties and looks at the future of the international tax regime.
Composed of concise but insightful chapters, this revised second edition will prove to be a key resource for students of international tax law, as well as for scholars within the fields of tax law, international business law and international commercial law.
目次
Contents: Part I: Overview of the International Tax Regime 1. Introduction: The International Tax Regime 2. Jurisdiction to Tax and Definitions 3. The Source Rules 4. Inbound Taxation: Passive Income 5. Inbound Taxation: Active Income 6. Transfer Pricing 7. Outbound Taxation: Passive Income 8. Outbound Taxation: Active Income 9. The Tax Treaty Network Part II: Selected Contemporary Issues 10. Three Steps Forward, One Step Back? Reflections on "Google Taxes" and the Destination-Based Corporate Tax 11. Evaluating BEPS 12. BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition? 13. Full Circle? The Single Tax Principle, BEPS, and the New US Model 14. A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits Index
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