Principles of International Taxation

Principles of International Taxation, Third Edition is a highly accessible text which provides a clear introduction to international taxation as well as more in-depth material on many essential areas of the subject. Whilst using some examples from the UK tax system, the book presents its material in a global context, explaining the variety of approaches used around the world to deal with the key issues that arise in international tax. The third edition contains 43 new sub-chapters covering areas such as: Interpretation of double tax treaties; Company residence after Smallwood; From credit to exemption method - the 2009 UK tax reforms; Dispute resolution under tax treaties: competent authority proceedings, use of binding arbitration clauses; HMRC6 following Gaines-Cooper; Worldwide review of practices on recognition of permanent establishments; Taxation of international trade in services; UK worldwide debt cap - rationale and structure; National and supranational initiatives to combat the use of tax havens; Finding a way forward: CFC legislation in EU Member States post Cadbury Schweppes. Principles of International Taxation deals with the legal issues and planning points central to international taxation, using simple examples and diagrams throughout to aid the reader's understanding. Lists of further reading are given at the end of each chapter, making the book suitable for academic as well as professional use. This is an essential title for lawyers and accountants practising in the area of international tax, candidates studying for Paper 1 of the Advanced Diploma in International Tax and for both postgraduate and undergraduate university students.