Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).

This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277