Overview of the Practice of International Taxation

Abstract

This is the long paper I wrote that I use as required reading for my introductory course to international taxation. The course name is "Taxation of Trans-Pacific Transactions" and is somewhat focused at the Asia-Pacific region due to my years residing and practicing there. However, the paper is broader, focusing on international taxation principles and tools generally found in the tax laws of many countries worldwide.

The paper includes a chapter providing background and other information on the G-20/OECD BEPS project.

Goals of Course: Develop thought processes and work methodologies for approaching cross-border planning; Gain knowledge of and skills in applying international tax principles and tools; Develop knowledge of and facility in using available English language research sources for Asia/Pacific countries (with a few exceptions, there will not be any focus on US tax law relating to international transactions since such will have been covered in the International Taxation Inbound and Outbound courses); Learn certain particulars of selected Asia/Pacific countries; Develop sensitivity to identify opportunities for the taxation systems of two or more countries to work well together for the advantage of the taxpayer and its business as well as sensitivity to risks when they do not work well together.

Keywords: International Taxation, BEPS, Sourcing of Income, Tax Havens, Transfer Pricing, TP, Forms of Organization, Source of Income, Residency, International taxation system, Territorial Taxation System, Foreign Tax Credit, Form of Doing Business, Tax Treaties, GAAR

JEL Classification: H21, H25, K34, E62