International Tax Primer

Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy.The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following:• role of the tax adviser in planning international transactions;• taxation of residents on foreign income and of nonresidents on domestic income;• mechanisms used to mitigate the risks to taxpayers of international double taxation;• transfer pricing rules to prevent the avoidance of tax by multinational corporations;• anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities;• overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and• challenges posed by taxation of income derived from the digital economy.An extensive glossary of international tax terms is included.With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.