"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."
Taxation of international transactions involves cross-border taxation issues such as foreign income, foreign tax credits, transfer pricing, and treaty issues. This topic is important for students who plan to work in multinational corporations or handle international tax matters.
Introduction to International Taxation: This topic covers the basics of international taxation, including the concepts of residency and source, double taxation, and tax treaties.
Transfer Pricing: This topic deals with the pricing of transactions between related parties in different tax jurisdictions. The focus is on ensuring that the prices charged for goods and services are consistent with what would be charged in arm's length transactions.
Taxation of Cross-Border Income: This topic covers the taxation of different types of income that are earned in different countries. The discussions typically cover foreign tax credits, exemptions, and withholding taxes.
Treaties and Agreements: This topic covers the various bilateral and multilateral agreements that governments have entered into in order to simplify the taxation of international transactions.
Permanent Establishments: This topic deals with the concept of permanent establishments, which is a key issue in the taxation of multinational corporations.
Taxation of Cross-Border Transactions: This topic covers the taxation of cross-border transactions, including the taxation of income from international services, royalties and dividends, and capital gains.
Asset Protection and Wealth Management: This topic deals with the various strategies that individuals and businesses can use to protect their assets and manage their wealth in different tax jurisdictions.
Cross-Border Mergers and Acquisitions: This topic covers the tax considerations involved in cross-border mergers and acquisitions.
Anti-Avoidance Rules and Regulations: This topic deals with the various anti-avoidance rules and regulations that countries have put in place to prevent the abuse of tax laws.
Tax Compliance: This topic covers the various compliance requirements that taxpayers need to meet when doing business in different countries.
Income Tax: This is a tax assessed on income, including salaries, wages, profits, and investment income.
Value Added Tax (VAT): A tax assessed on the value added to goods or services at each stage of production or distribution.
Withholding Tax: This is a tax deducted from a non-resident's income at the source by the resident taxpayer.
Excise Tax: A tax assessed on specific goods, such as tobacco, alcohol, fuel, or luxury goods.
Capital Gains Tax: This is a tax on the profit from the sale of a capital asset, such as stocks, bonds, or real estate.
Customs Duty: A tax assessed on goods imported into a country, usually based on the value of the goods.
Transfer Pricing: This is a tax on cross border transactions between related parties placed in different countries.
Estate Tax: This is a tax on the value of a deceased person's estate.
Sales Tax: A tax assessed on the sale of goods or services, usually at a fixed percentage of the price.
Thin Capitalization: This is a tax on less equity funds in compared to debt in a cross-border transaction.
"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."