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Description
Written by International Fiscal Services Ltd. a London-based firm of international tax consultants, The Principles of international Tax Planning represents a new approach to the subject. A widely held view is that international taxation must always be approached from a domestic perspective. But international tax is much more than glorified domestic tax. The issues, techniques and disciplines are quite different, and the aim of this book is to demonstrate the intricacies of international tax planning.
The book Is based around a case study of a fictitious Italian family with an abundance of personal and corporate tax issues, The work is presented in ten chapters, each covering a specific principle of international tax planning, such as 'Is the advice lawful? 'and'Why are trusts useful in tax planning?' Each chapter is split into two distinct sections. The first section analyses the laws applicable to the principle in question, and the second puts this into context by reference to the case study.
Accountants, bankers, lawyers, students, tax advisers and managers of trust companies will benefit from studying The Principles of International Tax Planning, either in depth or as a useful reference book. Because the book has been written by a firm specialising in international taxation, it considers the same questions and issues from the perspective of a number of different jurisdictions, such as France, Italy, South Africa, Switzerland, the UK and the US.
Whether you are just interested in international tax, or whether international tax is your livelihood, your horizons will be broadened by reading this book, and you will have fun while doing so.
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Contents
Chapter 1 - Is the Advice Lawful?
1.1 - Tax Avoidance v. tax evasion
1.2 - Anti-avoidance Legislation
1.3 - Anti-Mondey Laundering Legislation
1.4 - Information Exchange
1.5 - Mutual Collection of Taxes
1.6 - Exchange Control
Chapter 2 - Why are Trusts Useful in Tax Planning
2.1 - Basic Trust Concepts
2.2 - Trust recognition
2.3 - Trusts and Double Tax Treaties
2.4 - Types of Trust
2.5 - Common Trust Concerns
2.6 - Alterative to Trusts
Chapter 3 - What is the Importance of Source Compared to Residence?
3.1 - Source and situs
3.2 - Eu Directives
3.3 - Real Estate Taxation
3.4 - Employment and Consultancy Income
3.5 - Taxation of entertainers and Sportsmen
3.6 - Withholding Tax on Account of Income Tax
Chapter 4 - How can Tax Treaty Provisions Help?
4.1 - Functions of double tax Treatise
4.2 - Countries which are parties to double tax treaties
4.3 - Arrangement of the OECD Model Treaty
4.4 - Limitation on Benefits concept in double tax treaties
Chapter 5 - Can Domestic Taxation be mitigated by the use of Offshore Structures?
5.1 - Residence, domicile and citizenship
5.2 - Worldwide v. Territorial Principles of Taxation
5.3 - CFC Legislation and Apportionment of foreign passive income
5.4 - Anti-Avoidance provisions in respect of trusts
5.5 - Accessing offshore funds
5.6 - Tax amnesties
5.7 - Exit Tax
Chapter 6 - Is the Structure Artificial
6.1 - Sham Transactions
6.2 - Tax Schemes
6.3 - Substance over form, fraus legis and abus de droits
6.4 - General anti-avoidance rules (GAAR)
6.5 - Use of low-tax Jurisdiction
Chapter 7 - What are the Tax Implications of International Trade
7.1 - Entity Classification and General Tax Characteristics
7.2 - Commercial logic in Establishing entities
7.3 - Definition of Permanent Establishment
7.4 - E-Commerce
7.5 - Clearance under Advance Tax Rulings
Chapter 8 - What are Related - Party Transactions?
8.1 - Transfer Pricing
8.2 - Controlling prices and Profit Margins
8.3 - Adjustment of taxable Profit Margins
8.4 - Thin Capitalisation
Chapter 9 - What Expenses may Minimise Tax Liabilities
9.1 - Fundamental Considerations in Determining Allowable Expenses
9.2 - Review of Specific Deductions
9.3 - Constructive dividends
Chapter 10 - What other Taxes Need to be Considered
10.1 - Value Added Taxes
10.2 - Australian and Canadian GST
10.3 - Social Security Taxes
10.4 - Capital Taxes
Sources
Index
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