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Advance introduction to international tax / Reuven S. Avi-Yonah

By: Series: Advance legal introductionsPublication details: 2024 Edward Elgar United KindgomEdition: 3rdDescription: xiv, 188 pages 20 cmISBN:
  • 9781035339563 (Paperback)
Subject(s): DDC classification:
  • 343.04
Contents:
Acknowledgements - Abbreviations - PART I Overview of the international tax regime: 1 Introduction: the international tax regime - 2 Jurisdiction to tax and definitions - 3 The source rules - 4 Inbound taxation: passive income - 5 Inbound taxation: active income - 6 Transfer pricing - 7 Outbound taxation: passive income - 8 Outbound taxation: active income - 9 The tax treaty network - 10 The new international tax regime - PART II Selected contemporary issues: 11 BEPS 2.0: evolution or revolution? - 12 The origins of the new international tax regime - 13 Unilateralism, bilateralism and multilateralism - 14 The origins and prospects of Pillar One - 15 Pillar Two and the treaties - 16 Pillar Two and the credits - 17 Pillar Two and the BITs - 18 Conclusion - Bibliography - Index.
Summary: Elgar Advanced Introductions are stimulating and thoughtful introductions to major fields in the social sciences, business and law, expertly written by the world's leading scholars. Designed to be accessible yet rigorous, they offer concise and lucid surveys of the substantive and policy issues associated with discrete subject areas. This thoroughly revised third edition of the Advanced Introduction to International Tax Lawprovides an incisive overview of the key issues surrounding taxation and international law. Reuven S. Avi-Yonah explores the nuances of varying taxation systems using relevant and current case studies. Highlighting forward-thinking insights and research, this book explains tax treaties, how taxation is applied to income flowing across national borders, and how the limits imposed on such taxes have evolved over time. Avi-Yonah outlines the international tax regime regarding the foreign income of residents as well as the domestic income of non-residents, and how it has been dramatically modified in the last decade to address base erosion and profit shifting. Newly added chapters investigate contemporary issues such as BEPS 2.0 and the recent adoption of the OECD Two-Pillar solution by over 140 countries. Key Features: Defines the main principles of jurisdiction and how they apply to tax Critically analyses both inbound and outbound taxation, on both passive and active income Discusses transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source Concise and insightful, this third edition continues to be a crucial resource for students and scholars of international tax law, international business law and international commercial law, as well as fiscal policy and finance. It is also of great benefit to practitioners and policy-makers.
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Acknowledgements -
Abbreviations -
PART I Overview of the international tax regime:
1 Introduction: the international tax regime -
2 Jurisdiction to tax and definitions -
3 The source rules -
4 Inbound taxation: passive income -
5 Inbound taxation: active income -
6 Transfer pricing -
7 Outbound taxation: passive income -
8 Outbound taxation: active income -
9 The tax treaty network -
10 The new international tax regime -
PART II Selected contemporary issues:
11 BEPS 2.0: evolution or revolution? -
12 The origins of the new international tax regime -
13 Unilateralism, bilateralism and multilateralism -
14 The origins and prospects of Pillar One -
15 Pillar Two and the treaties -
16 Pillar Two and the credits -
17 Pillar Two and the BITs -
18 Conclusion -
Bibliography -
Index.

Elgar Advanced Introductions are stimulating and thoughtful introductions to major fields in the social sciences, business and law, expertly written by the world's leading scholars. Designed to be accessible yet rigorous, they offer concise and lucid surveys of the substantive and policy issues associated with discrete subject areas.
This thoroughly revised third edition of the Advanced Introduction to International Tax Lawprovides an incisive overview of the key issues surrounding taxation and international law. Reuven S. Avi-Yonah explores the nuances of varying taxation systems using relevant and current case studies.
Highlighting forward-thinking insights and research, this book explains tax treaties, how taxation is applied to income flowing across national borders, and how the limits imposed on such taxes have evolved over time. Avi-Yonah outlines the international tax regime regarding the foreign income of residents as well as the domestic income of non-residents, and how it has been dramatically modified in the last decade to address base erosion and profit shifting. Newly added chapters investigate contemporary issues such as BEPS 2.0 and the recent adoption of the OECD Two-Pillar solution by over 140 countries.
Key Features:
Defines the main principles of jurisdiction and how they apply to tax
Critically analyses both inbound and outbound taxation, on both passive and active income
Discusses transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source
Concise and insightful, this third edition continues to be a crucial resource for students and scholars of international tax law, international business law and international commercial law, as well as fiscal policy and finance. It is also of great benefit to practitioners and policy-makers.