Introduction to International Income Taxation

Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states.

Acknowledgments
Chapter 1 – Introduction
Section 1 – Taxes in a World of Sovereign States
Section 2 – The Method of International Taxation
Section 3 – Basic Concepts

Chapter 2 – Jurisdiction to Tax
Section 1 – Affirmation of Nexus
Section 2 – Tax Treaties

Chapter 3 – Access to Tax Treaties
Section 1 – Persons
Section 2 – Taxes
Section 3 – Territory
Section 4 – Entry into force

Chapter 4 – Allocation of Taxing Power
Section 1 – Source State Taxation
Section 2 – Residence State Taxation

Chapter 5 – Elimination of Double Taxation
Section 1 – Deduction Method
Section 2 – Exemption Method
Section 3 – Imputation Method
Section 4 – Exemption v. Imputation

Chapter 6 – Prevention of Tax Avoidance
Section 1 – Notion of Tax Avoidance
Section 2 – Principal Purpose Test
Section 3 – Taxing Erosion
Section 4 – Base Companies
Section 5 – Conduit Entities
Section 6 – Transfer Pricing
Section 7 – Interest Disallowance
Section 8 – Hybrid Arrangements
Section 9 – Domestic Anti Avoidance Rules

Chapter 7 – Prevention of Abuse by States
Section 1 – Domestic Law Override
Section 2 – Non-Discrimination
Section 3 – Harmful Tax Competition
Section 4 – Transfer Pricing

Chapter 8 – International Tax Procedure
Section 1 – Obtaining Information
Section 2 – Obtaining Refunds
Section 3 – Collection Assistance
Section 4 – Dispute Settlement

Chapter 9 – Conclusion
Appendix: Model International Tax Conventions
Summary Bibliography
Tables and Figures