Advanced Introduction to International Tax Law

Reuven S. Avi-Yonah

Advanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax.

DOI: dx.doi.org/10.4337/9781781952320

HB: 9781781952313
PB: 9781781952375
EISBN: 9781781952320

Advanced Introductions

Published in print:: 27 Feb 2015

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Front Matter
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  Cover
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  Half Title
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  Title Page
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  Copyright
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  Contents
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  Acknowledgements
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  Abbreviations

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PART I OVERVIEW OF THE INTERNATIONAL TAX REGIME
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  1 Introduction: the international tax regime
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  2 Jurisdiction to tax and definitions
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    2.1 Jurisdiction to tax
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    2.2 Defining residence
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  3 The source rules
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    3.1 Formal source rules
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    3.2 Substantive source rules
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    3.3 The problem of sourcing
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    3.4 Sourcing deductions
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  4 Inbound taxation: passive income
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    4.1 The general rule
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    4.2 The exceptions in general
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    4.3 The problem of distinguishing residents from non-residents
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  5 Inbound taxation: active income
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    5.1 Defining a TB or PE
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    5.2 Attribution of income
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    5.3 Special rules
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  6 Transfer pricing
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    6.1 The transfer pricing problem
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    6.2 The classical methods and their limitations
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    6.3 The profit-based methods
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    6.4 The future of transfer pricing
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  7 Outbound taxation: passive income
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    7.1 FIF rules
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    7.2 CFC rules
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  8 Outbound taxation: active income
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    8.1 The three hoops
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    8.2 The foreign tax credit limit
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    8.3 The indirect credit
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  9 The tax treaty network
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    9.1 The definitional articles
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    9.2 The substantive articles
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    9.3 The procedural articles
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    9.4 Exchange of information

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PART II SELECTED CONTEMPORARY ISSUES
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  10 Capital versus labor mobility
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    10.1 Can capital avoid US taxation by moving?
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    10.2 How immobile is labor?
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    10.3 Policy implications
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  11 The single tax principle
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    11.1 The historical origins of the single tax principle
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    11.2 Conclusion
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  12 The problem of non-discrimination
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    13 The future of transfer pricing
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    13.1 The problems of the ALS
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    13.2 The problems of formulary apportionment
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    13.3 Adopting formulas in the context of the ALS
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    13.4 Conclusion
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  14 Base erosion and profit shifting
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    14.1 Introduction
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    14.2 Why tax multinationals?
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    14.3 Taxing multinationals on global profits: a multilateral approach
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    14.4 Response to common critiques
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    14.5 Implications for developing countries
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    14.6 Can the proposal be adopted?
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    Appendix: can corporate tax rates be coordinated?
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  15 Conclusion: the future of the international tax regime
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    15.1 The problems
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    15.2 A possible solution

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Back Matter
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  Index

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Advanced Introduction to International Tax Law

Reuven S. Avi-Yonah

Advanced Introductions

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