International Tax Law and Practice

作者： Sue Cuthbertson; Belinda Ka Yin Law
出版商： Wolters Kluwer (HK) (formerly CCH)
ISBN: 9789887935698
出版时间 November 2019
规格： Paperback , 565 pages
适应领域： Hong Kong, International ? 免责申明：
Countri(es) stated herein are used as reference only

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The Taxation Institute of Hong Kong and Wolters Kluwer jointly publish International Tax Law and Practice which aims to assist students, tax professionals and businessmen to gain a good understanding of international tax law and practice, and prepare students for the Institute’s Certified Tax Adviser (CTA) Qualifying Examination Paper 3 – International Tax.

In an increasingly global business environment, individuals and corporations are exposed to taxation in jurisdictions where they are based, operate or from where they derive income. Many jurisdictions impose taxation under domestic tax rules on a tax residence basis, others on a jurisdictional or source basis. International taxation involves not only the study of the interaction between domestic legislation and international regulation to determine the taxing rights and the remedies available to alleviate double taxation, but also transfer pricing regulations to ensure that transactions are conducted on an “arm’s length” basis.

The Book includes the most up-to-date international taxation law, principles and practice and will help readers to understand:
- the basic principles of international taxation;
- the difference between economic and international double taxation and be able to demonstrate a thorough understanding of why
- international double taxation occurs;
- the means by which international double taxation may be avoided;
- the difference between unilateral and bilateral double taxation relief;
- the nature of double tax agreements (“DTAs”) and how the typical clauses operate; and
- common anti-avoidance provisions in tax legislation to counter types of international tax planning.
Written by seasoned tax practitioners and reviewed by renowned academics and practitioners, International Tax Law and Practice is a comprehensive and up-to-date reference for persons who wish to understand more about international taxation.
1. Introduction to International Taxation
2. Right of a Jurisdiction to Impose Tax
3. Basis of Taxation
4. Typical Rules for Determining the Source of Income
5. Common Methods for Taxing Different Types of Income
6. Double Taxation Relief
7. Role of the OECD in International Taxation
8. Introduction to Double Tax Agreements
9. Principle Articles of the OECD Model DTA
10. Treaty Shopping and Counter-Measures of a Taxing Jurisdiction
11. Double Tax Agreement Entered into by Hong Kong and the PRC
12. Transfer Pricing
13. Thin Capitalisation and Earnings-Stripping Rules
14. Controlled Foreign Company (CFC) Rules
15. Other Issues
The Taxation Institute of Hong Kong

The Taxation Institute of Hong Kong, established in 1972, has been serving the tax profession in Hong Kong for over 46 years. The main objectives of the Institute are to promote the study of taxation, enhance the professional and technical standard of tax professionals, and provide a platform for the exchange of taxation knowledge.

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