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详细
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.
Systems of taxation deviate between jurisdictions, and contrasting, income based levies on both individuals and enterprises are implemented depending on the nature or source of income. This dynamic book explores the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as acting as an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.
Key features include:
• defines and discusses the main types of jurisdiction to tax
• delineates the source of income that is crucial for taxing non-residents and foreign tax credit
• explains in depth both inbound and outbound taxation on both passive and active income
• discussion of transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source
• explains how the above elements are influenced by tax treaties and looks at the future of the international tax regime.
Composed of succinct but highly informative chapters, this engaging introduction will prove to be an essential platform for students of international tax law, as well as for scholars with a particular interest in tax law, international business law and international commercial law.
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Part I Overview of the International Tax Regime 1. Introduction: The International Tax Regime 2. Jurisdiction to Tax and Definitions 3. The Source Rules 4. Inbound Taxation: Passive Income 5. Inbound Taxation: Active Income 6. Transfer Pricing 7. Outbound Taxation: Passive Income 8. Outbound Taxation: Active Income 9. The Tax Treaty Network Part II Selected Contemporary Issues 10. Capital Versus Labor Mobility 11. The Single Tax Principle 12. The Problem of Non-discrimination 13. The Future of Transfer Pricing 14. Base Erosion and Profit Shifting 15. Conclusion: The Future of the International Tax Regime
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Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan Law School, US
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‘Avi-Yonah’s Advanced Introduction to International Tax Law is a compact and accessible guide to the field. In effect, he has given us two books in one. The first is a very useful general guide to the basics of the rules and how they work in practice, with illuminating international comparisons to the often distinctive US rules. The second is a clear and spirited defense of Avi-Yonah’s particular views about international tax policy. These do not attract consensus in the field – nor do anyone else’s views – but they can help stimulate further thinking about these complicated and important issues.’
– Daniel Shaviro, New York University, US
