Description:-Constant changes in international tax make it increasingly difficult for companies to operate in more than one jurisdiction without significant support from their tax advisers. In recent times, many long-standing tax planning techniques have been challenged. This extensive work written by Zoe Wyatt considers those changes and deals with all the major issues in international tax planning, including controlled foreign companies, EU law, double tax relief, withholding taxes and transfer pricing. New to this edition:A new chapter on the UK Diverted Profits Tax (DPT)A new chapter on the Changing Tax Landscape, covering the OECDCommon Reporting Standard and OECD Country-by-Country reporting recommendationSummary of Fisher v Revenue and Customs Comrs 2014 and the compatibility of the Transfer of Assets Abroad Regime with EU lawImpact of the latest decision of the Marks & Spencer case from the Court of Justice of the European Union (CJEU) on cross-border loss reliefA more detailed commentary on relevant BEPS Actions 1ΓÇô10, 13 and 15, as at September 2015, covering:Proposed changes to the definition of a ‘permanent establishment’Proposed changes to counter Double Tax Agreement abuseNew OECD guidance on the attribution of value in relation to intangibles for transfer pricing purposesHow the Multilateral Instrument proposed in BEPS Action 15 seeks to implement swiftly the final BEPS recommendationsEach key topic is illustrated with short examples, tables and checklists with transaction-based case studies of overseas tax systems including Australia, Canada, China, France, Germany, India and the United States.
1st Edition 2016