International taxation

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The study of how taxes are imposed on international transactions and how they affect trade and investment.

Introduction to International Taxation: This topic covers the fundamentals of international taxation, tax treaties, double taxation, and source of income rules.
Taxation of International Transactions: This topic covers the taxation of cross-border transactions, such as mergers and acquisitions, transfer pricing, and international financial transactions.
Taxation of Foreign and U.S. Persons: This topic covers the tax implications for both foreign and U.S. taxpayers, such as withholding tax requirements and tax residency rules.
Tax Havens and Offshore Tax Planning: This topic deals with tax avoidance and tax planning strategies to minimize tax liability through the use of tax havens and offshore structures.
Transfer Pricing: This topic covers the taxation of transactions between related parties, including transfer pricing regulations, documentation requirements, and dispute resolution mechanisms.
Taxation of Intellectual Property: This topic covers the taxation of intellectual property rights, including patents, trademarks, and copyrights, and the tax implications of licensing and transfer of such rights.
Taxation of E-commerce and Digital Business: This topic covers the tax implications of online sales, digital products, and the taxation of digital service providers.
Value-Added Tax (VAT) and Customs Duties: This topic covers cross-border VAT and customs duties issues, including VAT registration, invoicing, and the treatment of goods imported/exported.
Tax Treaty Interpretation: This topic deals with the interpretation and application of tax treaties, including issues related to tax residency, permanent establishment, and the allocation of taxing rights.
Anti-avoidance Rules: This topic covers anti-avoidance measures, such as general anti-avoidance rules, controlled foreign company rules, and hybrid mismatch rules, aimed at preventing tax avoidance and promoting tax transparency.
Corporate tax: This is the tax imposed on the earnings of a business entity or corporation that is taxed by the jurisdiction in which it operates.
Value-added tax (VAT): VAT is a consumption tax imposed on the value added at each stage of production and distribution.
Transfer pricing: This is a tax strategy that involves setting prices for goods and services sold between different subsidiaries of the same multinational company.
Withholding tax: This is a tax deducted at the source of income, often levied on non-residents earning income from within a country.
Income tax: Often referred to as personal income tax, it is the tax levied on an individual's income as determined by the jurisdiction they reside in.
Estate tax: This is the tax imposed on the total value of the assets of an individual at the time of their death.
Gift tax: This is a tax imposed on gifts of cash or property that exceed a certain value threshold, often given by an individual during their lifetime.
Tariffs: These are taxes on imports and exports, levied by governments to protect their domestic industries and create a revenue stream for the government.
Excise duties: These are taxes imposed on specific goods such as alcohol, tobacco, gasoline, and luxury items.
Environmental taxes: These are taxes imposed on companies or individuals who pollute the environment or cause environmental damage.
Tax treaties: These are agreements between two or more countries including taxation and solving jurisdiction issues.
International tax planning: It includes the adoption of various strategies intended to minimize a company's tax obligations across different jurisdictions.
"International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be."
"Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income."
"The manner of limitation generally takes the form of a territorial, residence-based, or exclusionary system."
"Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more."
"These variations create the potential for double taxation (where the same income is taxed by different countries) and no taxation (where income is not taxed by any country)."
"Income tax systems may impose tax on local income only or on worldwide income. Generally, where worldwide income is taxed, reductions of tax or foreign credits are provided for taxes paid to other jurisdictions."
"Multinational corporations usually employ international tax specialists, a specialty among both lawyers and accountants, to decrease their worldwide tax liabilities."
"Jurisdictions often impose rules relating to shifting income among commonly controlled parties, often referred to as transfer pricing rules."
"Residency-based systems are subject to taxpayer attempts to defer recognition of income through the use of related parties."
"A few jurisdictions impose rules limiting such deferral ("anti-deferral" regimes)."
"Deferral is also specifically authorized by some governments for particular social purposes or other grounds."
"Agreements among governments (treaties) often attempt to determine who should be entitled to tax what."
"Most tax treaties provide for at least a skeleton mechanism for the resolution of disputes between the parties."