Principles of International Taxation (Bloomsbury Professional) provides an accessible introduction to international taxation as well as some more in-depth material on many essential areas of the subject. Whilst using some examples from the UK tax system, the book presents its material in a global context, explaining the variety of approaches used around the world to deal with the key issues that arise in international tax. The third edition covers such areas as interpretation of double tax treaties, company residence after Smallwood and from credit to exemption method - the 2009 UK tax reforms. The text uses simple examples and diagrams throughout and gives lists of further reading, making it suitable for academic as well as professional use.
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Part 1 Introduction to Tax
Part 2 Introduction to International Tax
Chapter 2 Introduction to International Taxation
Part 3 International Tax Planning
Chapter 8 Permanent Establishments
The exception for activities which are 'preparatory or auxiliary'
The extent of the exposure to tax in the state where the PE is located
Permanent establishments: the extended definitions in the UN Model Tax Convention
The importance of the definition of permanent establishment under a state's domestic law
Chapter 11 Individuals Working Abroad
The taxation of gains from share incentives for internationally mobile employees
Tax treatment of employees resident but not ordinarily resident in the UK
The 2011 UK proposals for a statutory test of residence for individuals
Tax treatment of employees who have a foreign domicile and work for a non-resident employer
Summary of effect of residence and domicile rules on taxation of earnings
National Insurance contributions for employees going to work abroad
Part 4 International Tax Avoidance
Part 5 International Tax Policy