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International Taxation of Energy Production and Distribution

International Taxation of Energy Production and Distribution

作者： John Abrahamson
出版商： Kluwer Law International
ISBN: 9789041191014
出版时间 May 2018
规格： Hardback
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,692.60

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International Taxation of Energy Production and Distribution introduces and examines significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth approach to policy and practice in the field worldwide, the author focuses on the international tax framework and the tax regimes in leading energy producing and consuming countries.

What’s in this book:
The taxation issues covered include the following:
- upstream oil and gas and mining taxes;
- incentives for renewable energy;
- carbon taxes and emission trading regimes;
- dividend, interest, and royalty flows;
- foreign tax credits;
- permanent establishments;
- mergers and acquisitions;
- taxation issues for derivatives and hedging;
- transfer pricing;
- regional purchasing, marketing, service, and intangible property structures;
- free trade agreements and customs unions;
- dispute resolution; and
- tax administration and risk management.
Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples and gain practice in identifying and discussing relevant international taxation issues.

How this will help you:
As a practical approach to highlight the relevant issues in international energy taxation, this book serves as a springboard for problem-solving and analysis of the related taxation issues. It is a handbook for corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics to navigate confidently through the maze of the taxation issues in the energy industry.
Preface

CHAPTER 1
Introduction

CHAPTER 2
Overview of International Taxation and OECD BEPS Measures

CHAPTER 3
Tax Treaty Provisions

CHAPTER 4
Examples of Country Fiscal Systems

CHAPTER 5
Upstream Oil and Gas Taxation: Exploration and Production

CHAPTER 6
Tankers and Bulk Carriers

CHAPTER 7
Pipelines

CHAPTER 8
Downstream Taxation: Refineries and Processing Plants

CHAPTER 9
Coal Exploration and Production

CHAPTER 10
Power Stations and Electricity Networks

CHAPTER 11
Renewable Energy: Supply, Funding, and Taxation Incentives

CHAPTER 12
Carbon Taxes and Emissions Trading Schemes

CHAPTER 13
Contractor Services and Permanent Establishments (PEs)

CHAPTER 14
Value Added Tax

CHAPTER 15
Customs Duties and Tariffs

CHAPTER 16
Holding Companies, Dividends, and Profit Distributions

CHAPTER 17
Interest Deductions in Subsidiaries and Thin Capitalisation

CHAPTER 18
Interest Flows and Hybrid Arrangements

CHAPTER 19
Capital Gains, Group Restructures, and Private Equity

CHAPTER 20
Group Procurement Companies

CHAPTER 21
Group Marketing Companies

CHAPTER 22
Group R&D and Intangible Property Companies

CHAPTER 23
Group Treasury and In-House Banking Companies

CHAPTER 24
Group Service Companies

CHAPTER 25
Group Insurance Companies

CHAPTER 26
Mergers and Acquisitions

CHAPTER 27
Asset Leasing

CHAPTER 28
Tax Havens and Controlled Foreign Corporations Rules

CHAPTER 29
Introduction to Transfer Pricing

CHAPTER 30
Transfer Pricing Issues for Energy Production and Distribution

CHAPTER 31
Intangibles and Transfer Pricing

CHAPTER 32
Intra-group Services, Cost Contribution Arrangements, and Transfer Pricing

CHAPTER 33
Loan Financing, Interest Payments, and Transfer Pricing

CHAPTER 34
OECD BEPS and the Changing Tax Environment

CHAPTER 35
Design of Energy Fiscal Systems

CHAPTER 36
General Conclusions

Case Studies

CASE STUDY 1
Renewable Energy: The Offshore Wind Farm Project, Income Flows, and Permanent Establishments (PE)

CASE STUDY 2
Upstream Oil and Gas: The New Production Sharing Contract (PSC)

CASE STUDY 3
Treasury and Finance: The Group Treasury Centre, Loans, and Derivatives

CASE STUDY 4
Mergers and Acquisition: Private Equity Sale of an Electricity Transmission Network

CASE STUDY 5
Group Research and Development (R&D): Cost Contribution Arrangements (CCA)

CASE STUDY 6
Group Technology: The New Battery Storage System and Tax Treaties

CASE STUDY 7
Group Technology: The Solar Power Station, Transfer Pricing, and Mutual Agreement Procedures (MAP)

CASE STUDY 8
Group Marketing: The Liquefied Natural Gas (LNG) Marketing

Appendices

APPENDIX I
OECD Model Tax Convention 2017: Condensed Version

APPENDIX II
North America Free Trade Agreement (NAFTA): Extracts

APPENDIX III
European Union: Union Customs Code

APPENDIX IV
European Union: Union Customs Code

Table of Cases

Table of Statutes and Directives

Table of Treaties and International Agreements

Index

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