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Author: John Abrahamson Publisher: Kluwer Law International B.V. ISBN: 9403510951 Category : Law Languages : en Pages : 448
Book Description
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Author: John Abrahamson Publisher: Kluwer Law International B.V. ISBN: 9403510951 Category : Law Languages : en Pages : 448
Book Description
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Author: Felix I. Lessambo Publisher: Springer ISBN: 1349949353 Category : Business & Economics Languages : en Pages : 378
Book Description
This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.
Author: John Abrahamson Publisher: Tolley ISBN: 9780754551843 Category : Corporations Languages : en Pages : 432
Book Description
This book introduces and discusses international tax issues relating to corporate finance, group treasury, and banking operations. The book is intended to benefit accountants, lawyers, economists, financial managers and government officials by explaining practical corporate finance international tax issues. These issues include: examples of country tax regimes; corporate finance including issuing shares; debt instruments; bank loans; investment banking activities; and alternative finance such as crowdfunding; microfinance and alternative energy funding; and international tax issues relating to interest and dividend flows; capital gains; and foreign tax credits. The book reviews related topics, including: mergers and acquisitions funding; asset and project finance; securitisation; derivatives; hybrid securities and entities; Islamic financing; bank capital structures; group treasury companies; debt restructuring; and transfer pricing issues. The book is based on Corporate Finance and International Taxation courses presented by the author in London, Paris, Zurich, Lugano, Rio de Janeiro, Mexico City, Hong Kong and Singapore.
Author: Ms.Grace Weishi Gu Publisher: International Monetary Fund ISBN: 1475572204 Category : Business & Economics Languages : en Pages : 35
Book Description
This paper explores how corporate taxes affect the financial structure of multinational banks. Guided by a simple theory of optimal capital structure it tests (i) whether corporate taxes induce subsidiary banks to raise their debt-asset ratio in light of the traditional debt bias; and (ii) whether international corporate tax differentials vis-a-vis foreign subsidiary banks affect the intra-bank capital structure through international debt shifting. Using a novel subsidiary-level dataset for 558 commercial bank subsidiaries of the 86 largest multinational banks in the world, we find that taxes matter significantly, through both the traditional debt bias channel and the international debt shifting that is due to the international tax differentials. The latter channel is more robust and tends to be quantitatively more important. Our results imply that taxation causes significant international debt spillovers through multinational banks, which has potentially important implications for tax policy.
Author: Arthur Young International Banking Group Publisher: ISBN: Category : Banks and banking Languages : en Pages : 448
Book Description
Monograph on the corporate income tax of banks in various countries in the world as a comparative study prepared on a common outline by various authors. Countries covered are: Australia, Belgium, Canada, Denmark, France, West Germany, Hong Kong, Italy, Japan, Luxembourg, the Netherlands, New Zealand, Singapore, Spain, Sweden, Switzerland, United Kingdom, U.S.A.
Author: Mr.Michael Keen Publisher: International Monetary Fund ISBN: 1463902174 Category : Business & Economics Languages : en Pages : 41
Book Description
The financial crisis has prompted a reconsideration of the taxation of financial institutions, with practice outstripping principle: France, Germany, the United Kingdom and several other European countries have now introduced some form of bank tax, and the U.S. administration has revived its own proposal for such a charge. This paper considers the structure, appropriate rate, and revenue yield of corrective taxation of financial institutions addressed to two externalities, consequent on excessive risk-taking, prominent in the crisis: those that arise when such institutions are simply allowed to collapse, and those that arise when, to avoid the harm this would cause, their creditors are bailed out. It also asks whether corrective taxation or a regulatory capital requirement is the better way to address these concerns. The results suggest a potential role for taxing bank borrowing, perhaps as an adjunct to minimum capital requirements, at marginal rates that rise quite sharply at low capital ratios (but are likely lower when the government cannot commit to its bailout policy), reaching levels higher than those of the bank taxes so far adopted or proposed.
Author: OECD Publisher: OECD Publishing ISBN: 926406785X Category : Languages : en Pages : 136
Book Description
This book analyses the nature of banking, its complex financing transactions and how they are used by both banks and their clients in tax planning. It also explores the processes that banks use to manage tax risk and the prevention, detection and response strategies applied by revenue bodies.
Author: Michael Kobetsky Publisher: Cambridge University Press ISBN: 1139500228 Category : Law Languages : en Pages : 469
Book Description
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Author: Martin Zagler Publisher: Routledge ISBN: 1136952454 Category : Business & Economics Languages : en Pages : 208
Book Description
International taxation is a major research topic, and for a field of research at the intersection of so many disciplines there has been surprisingly little done across disciplinary boundaries. This book fills the gap by combining teams from business, economics, information science, law and political science to offer a unique and innovative approach to the issue of international tax coordination. All the chapters are written in collaboration between at least two authors from two different disciplines. This approach offers a rich and nuanced understanding of the many issues of international tax coordination. The book collects seven papers, each one a valuable contribution in itself, beginning with current problems of international taxation and finishing with potential solutions. The essays explore current EU legislation, tax avoidance and tax fraud, as well as double tax agreements, dividend repatriation and hybrid finance and tax planning. Providing methodological answers to the question of how to conduct interdisciplinary research, the book also gives an accessible introduction into research questions and answers that are important in related disciplines for scholars in various areas. This book will be of interest to postgraduates and researchers in the fields of economics, business, informational science, law and political science, as well as to professional accountants and tax lawyers.
Author: John Abrahamson
Author: John Abrahamson
Author: Stanley I. Langbein
Author: Felix I. Lessambo
Author: John Abrahamson
Author: Ms.Grace Weishi Gu
Author: Arthur Young International Banking Group
Author: Mr.Michael Keen
Author: OECD
Author: Michael Kobetsky
Author: Martin Zagler