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International Taxation of Banking

International Taxation of Banking

  • 作者:
  • 出版商: Kluwer Law International
  • ISBN: 9789403510941
  • 出版时间 February 2020
  • 规格: Hardback
  • 适应领域: International ? 免责申明:
    Countri(es) stated herein are used as reference only

List Price: ¥1,655.40

¥1,605.74 Save ¥49.66 (3%)

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  • 描述 
  • 大纲 
  • 详细

    About this book:

    International Taxation of Banking introduces and analyses the international tax issues which relate to international banking activities. 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, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups.

    What’s in this book:

    The content of this book clearly identifies and explains the management of research and development and intangible property used in the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book 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.

    How this will help you:

    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 serve as 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.

  • 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

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