A reference guide to international taxation: profiting from your international operations
This text aims to help the reader, with or without o tax background, understand tax implications in the world of international trade. It is divided into four sections, tax systems, double taxation, tax havens and international tax planning. Topics include taxes applicable to business operations, taxable entities, taxation bases, direct taxation, taxation of business profits, capital gains, transfers by gifts and on death.
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DoubleTaxation Relief for Business Income
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accounting activities allowances amount antiavoidance apply arise Article assessment assets business profits capital gains tax citizen citizenship competent authorities Contracting Convention country of residence country of source currency deductible deemed defined determining direct taxation dividends domestic tax domicile double taxation double-taxation agreements double-taxation relief double-taxation treaty effect enterprise entity estate duty example exchange controls exemption expenses fiscal residence fixed base foreign sales corporation foreign tax credit France gift tax high-tax countries Hong Kong immovable property imposed income tax individual interest investment Netherlands nonresident OECD operations payments percent permanent establishment problems receipts regard relating respect revenue royalties sales tax shareholders Switzerland tax authorities tax avoidance tax costs tax havens tax laws tax liability tax paid tax purposes tax rates tax rules tax-haven countries taxable profits taxpayer term tion trade transactions transfer trust U.S. law U.S. tax United Kingdom wealth tax withholding tax