Written in simple and straightforward terms, the author not only looks at all the principal types of tax system around the world, outlining their interaction, but also deals with the fundamental principles of international tax planning. Throughout, all the issues involved in international tax are considered from a multinational perspective, rather than in the light of one particular tax regime. This approach will provide all those in business and professional practice with a wider view of the commercial ramifications of international tax planing. Written by an author with considerable expertise in this field, The Principles of International Taxation - A Multinational Perspective should be on the shelves of all those with dealings in international taxation.
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Editorial Reviews
From the Publisher
The nature of the work has also changed. In the old days, the typical client was a parent company with a range of operating subsidiaries whose management was astonished and delighted to find that there were more fiscally efficient, but still fairly simple, ways of setting up its structure. Today's financial markets are far more international and the real fun is to be had with sophisticated financial instruments and hedging techniques, and with cross-border mergers. In the latter case, one problem for tax advisers is often to persuade the gung-ho deals merchants to slow down just for a few days so we can get the tax planning right. Only too often they don't, and another few million accrues unnecessarily to the ungrateful tax collectors of this world.
Contrary to popular superstition, the serious end of the international tax profession is not and never has been concerned primarily with aggressive tax avoidance using tax havens, transfer pricing, and double-dipping, although these are the icing on the cake. The real problems come when a company, perfectly prepared to be a good corporate citizen of all the countries in which it operates, finds that their requirements mutually conflict. The adviser has to pick his way through a minefield to avoid being taxed more than once on the same profit. Over the years, the opportunity for avoidance has been seriously constrained by legislation. The corollary is that the task of the adviser has been made more challenging by the need to navigate essentially straightforward transactions though traps set up to catch those whose intentions were less innocent.
In 1974 I published my own book on international tax planning which readers seem to have found useful for far longer than its expected shelf life of two or three years. Having never, somehow, managed to produce another edition, I am delighted that my old friend, Adrian Ogley, has taken up the challenge with this excellent general study. It is a bid subject and his book inevitably does not claim to claim all the answers. At least his readers, and there should be many of them, will know what questions to ask and will appreciate the richness, diversity and challenge of this fascinating subject.
John Chown, J.F. Chown & Company Limited 51 Lafone Street, London SE1 2LX
From the Author
The multinational perspective, to which reference is made in the title, means that this book is concerned exclusively with international tax in so far as it affects multinational companies (and not individuals). It also means that the author has sought to adopt a multinational perspective in considering the issues involved in international tax, as opposed to simply considering these in the light of the tax legislation of one particular, national regime. Although the author's background, practical experience and reading will inevitably reveal a cultural bias, it is hoped that this will not detract from the achievement of this wider aim.
So far as the structure of this work is concerned, it is divided into two distinct parts. After the introductory chapter, Part I of the book deals with the principal types of tax system and their interaction, with special emphasis on the question of double taxation at the shareholder level. There then follows a chapter entitled double taxation and double tax agreements which deals with the double taxation of profits accruing within companies and explains how double tax agreements seek to avoid, or at least mitigate this.
The proposals for harmonising direct, corporate taxes in Europe are then considered with particular reference to the choice of tax system. The chapter on stapled stocks and hybrid structures explores innovative structures which have been devised by a number of multinationals to overcome the problem of double (or multiple) taxation of shareholders which would otherwise arise as a result of the inherent incompatibility of tax systems; this problem is either not addressed or inadequately addressed by the majority of double tax agreements.
Part II deals with the principles of international tax planning. The objectives of international tax planning have been described as the diversion, extraction and distribution of profits from high to low tax jurisdictions. Because the selection of the most appropriate means of finance is fundamental to this process, a separate chapter is devoted to the role of international financing and overseas finance companies in tax planning. Tax havens, by their very nature, offer the ultimate low-tax refuge for profits and accordingly a separate chapter outlines their attributes as well as their uses and abuses. This is followed by a chapter describing certain specific corporate vehicles which are used for the diversion or extraction of profits ie, licensing, captive insurance and other service companies. The distribution of profits is dealt with in a chapter on the function and location of holding companies. A chapter on the Netherlands and Netherlands Antilles in international tax planning explores not only those features of the Dutch tax system which have made it a focal point in international tax planning, but also its interaction with the tax system of the Netherlands Antilles. However, no book on this subject would be complete without outlining the rapid growth of anti-avoidance measures in the international arena.
As some readers may prefer to dip into the book, as opposed to reading it from cover to cover, individual chapters are largely self-contained in their treatment of the topic under consideration. Where there are cross-references to other chapters, these simply serve to direct the reader to another part of the text where the same subject matter is dealt with in greater depth.
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