Based on the findings of a commission chaired by James Mirrlees, this volume presents a coherent picture of tax reform whose aim is to identify the characteristics of a good tax system for any open developed economy, assess the extent to which the UK tax system conforms to these ideals, and recommend how it might be reformed in that direction.

The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.

You are paying much more in tax than you think you are What Everyone Needs to Know About Tax takes an entertaining and informative look at the UK tax system in all its glory to show you just how much you pay, how the money is collected and how it affects ordinary people every day. Giving context to recent controversies including the Panama Papers, tax avoidance by multinationals, Brexit and more, this book provides a straightforward explanation of tax and the policy behind it for non-specialists — no accounting or legal knowledge is required. The system's underlying logic is illustrated through three 'golden rules' that explain many of the UK tax regime's oddities, and the discussion focuses on the way things are rather than utopian ideas about how they might be. Case studies show how the VAT on a plumber's bill all adds up; why fraudsters made a movie to throw HMRC off their scent; how a wealthy couple can pay so little tax on a six-figure income; and the way tracing the money you paid for your iPad sheds light why the EU is demanding Apple pay billions extra in tax. Ever the political battlefield, tax is too important for you to rely on media hype for information. It affects everyone, every day, and it pays for voters and taxpayers to know more. This book leaves aside technical detail and the arcana of the tax code to give you a real-world look at how tax works. Learn about the many ways that the tax system separates us from our money Discover how Brexit could change the way we pay taxes Understand how changing tax policy affects people's everyday lives See through the rhetoric surrounding controversies in the media With tax, we have to admit that there are no easy answers. No one enjoys paying them, but without them, the Government would shut down. Seeing through politicians' cant and superficial press coverage is critical for your ability to make the decisions that benefit you; What Everyone Needs to Know About Tax gives you the background and foundational knowledge you need to be a well-informed taxpayer.

This unique book is a concise but complete tax planning manual for those advising high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members. Guide to US/UK Private Wealth Tax Planning covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with: A quick reference summary of the UK and US rules applicable to your clients; A comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US; Optimal income and gains tax planning for foreign trusts with UK or US beneficiaries; Integrated UK and US tax planning solutions for clients exposed to both UK and US tax. Previous edition ISBN: 9781845920272

Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

UK Taxation for Students is fully updated for Finance Act 2023. This book can be used either on its own or in conjunction with other texts. It is, however, completely self-contained. This book is written in a user-friendly manner. It includes over 180 worked examples plus true and false quizzes and a further 101 questions for readers. Complex jargon is avoided. Simple English is used. This book also assumes absolutely no prior knowledge about UK taxation. This book covers the five main UK taxes: income tax (paid by individuals), capital gains tax (paid by individuals), corporation tax (paid by companies), value added tax (levied on consumers by businesses), and inheritance tax (normally payable on the death of an individual), and National Insurance Contributions. We have seen some significant tax policy changes since the last edition, and then many of these have already been reversed! Making Tax Digital for Self-Assessment has been deferred again but we have substantial changes introduced, including to the taxation of self-employed individuals and the first increase in the rate of corporation tax since 2007. For students at undergraduate level. Also suitable for ACCA, ICAEW and AAT. CONTENTS TAX RATES AND ALLOWANCES CHAPTER 1: Introduction CHAPTER 2: Income Tax: General Principles and Tax Rates CHAPTER 3: Income Tax Computations CHAPTER 4: Extending the Rate Bands CHAPTER 5: Income from a property business CHAPTER 6: Trading profits CHAPTER 7: Capital Allowances CHAPTER 8: Sole Trader Business Losses CHAPTER 9: Partnerships 76 CHAPTER 10: Employee Taxation 82 CHAPTER 11: Personal Tax: Overseas Aspects CHAPTER 12: Pensions 111 CHAPTER 13: Capital Gains Tax: General Principles CHAPTER 14: CGT: Shares and securities CHAPTER 15: CGT: Business Reliefs CHAPTER 16: Corporation Tax: General Principles CHAPTER 17: Chargeable Gains for Companies CHAPTER 18: Company Losses CHAPTER 19: Groups of Companies CHAPTER 20: National Insurance Contributions (NICs) CHAPTER 21: Tax Administration for Individuals CHAPTER 22: Tax Administration for Corporation Tax and Employers CHAPTER 23: Value Added Tax CHAPTER 24: Inheritance Tax an introduction APPENDIX 1: How to Study Taxation: Some practical tips APPENDIX 2: Questions for Students APPENDIX 3: True or False Questions Index

Tax revenues pay for many public services, including roads, health care, and education. However, it has become a contentious political issue of public debate. In this volume, Stephen Smith explains its history and its main principles; arguing that we'd all benefit from an understanding of the role of taxation in society.