Preface
List of Abbreviations
CHAPTER 1
Introduction
CHAPTER 2
The Banking Regulatory Framework
CHAPTER 3
Retail and Commercial Banking
CHAPTER 4
Investment Banking
CHAPTER 5
Introduction to International Tax
CHAPTER 6
Tax Treaties
CHAPTER 7
OECD BEPS Developments
CHAPTER 8
Bank Parent Companies
CHAPTER 9
Bank Branches
CHAPTER 10
Other Bank Permanent Establishments
CHAPTER 11
Representative Offices
CHAPTER 12
Derivatives
CHAPTER 13
Loan Provisions and Debt Restructuring
CHAPTER 14
Value Added Tax: VAT
CHAPTER 15
Bank Taxes: Financial Transaction Taxes and Bank Levies
CHAPTER 16
Dividends and Profit Distributions
CHAPTER 17
Group Treasury, Interest Flows and Thin Capitalisation
CHAPTER 18
Intangible Property: IP
CHAPTER 19
Tax Havens and Controlled Foreign Companies: CFCs
CHAPTER 20
Introduction to Transfer Pricing
CHAPTER 21
Transfer Pricing and Bank Branch Attribution
CHAPTER 22
Transfer Pricing and Global Trading
CHAPTER 23
Transfer Pricing and Loans
CHAPTER 24
Transfer Pricing and Intangibles
CHAPTER 25
Transfer Pricing and Services
CHAPTER 26
Islamic Banking
CHAPTER 27
Green Banking
CHAPTER 28
Microfinance Banking
CHAPTER 29
Financial Technology: Fintech
CHAPTER 30
Shadow Banking
CHAPTER 31
Automatic Exchange of Information: CRS and FATCA
CHAPTER 32
Taxation Policy Developments
CHAPTER 33
General Conclusions
Case Studies
Case Study 1
The Malaysia Branch: Permanent Establishments and Treaties
Case Study 2
The Korean Bank Acquisition: Group Interest Deductions
Case Study 3
Group Technology: Global Risk Management Cloud Software and Tax Treaties
Case Study 4
The Italian Branch: Branch Attribution
Case Study 5
Branch Profit Attribution: Corporate Loans and Global Trading
Case Study 6
The Group Advertising Centre: Transfer Pricing Dispute
Appendix
OECD Model Tax Convention 2017
Table of Cases
Table of Statutes and Directives
Table of Treaties and International Agreements
Index
