Principles of international taxation

VOLUME I PREFACE ABOUT THE AUTHOR I AN OVERVIEW OF INTERNATIONAL TAXATION 1. Objectives of Global Tax Systems 2. International Tax Conflicts and Double Taxation 3. Double Tax Treaties 4. Domestic Tax Systems 5. International Offshore Financial Centres 6. Anti-avoidance Measures 7. International Tax Planning 8. Structure of the Book 9. Suggested Further Reading II PRINCIPLES OF INTERNATIONAL TAX LAW 1. International tax law 2. Interpretation of Tax Treaties 3. Some legal Decisions on Treaty Interpretations 4. Applicability of Tax Treaties 5. Model Tax Convention 6. Multilateral Tax Agreements 7. European Union 8. Suggested Further Reading III MODEL TAX CONVENTIONS ON DOUBLE TAX AVOIDANCE 1. OECD Model Convention (OECD MC) 2. UN Model Convention (UN MC) 3. US Model Convention (US MC) 4. Articles in Model Conventions 5. Bilateral Tax Treaties 6. Suggested Further Reading IV IMPACT OF DOMESTIC TAX SYSTEMS 1. Introduction 2. Tax Residence or Fiscal Domicile 3. Source of Income or Gain 4. Basis of Tax Computation 5. Treatment of Tax Losses 6. Tax Consolidation Rules (Group Taxation) 7. Passive Income 8. Foreign Tax Relief 9. Suggested Further Reading INTERNATIONAL TAX GLOSSARY EXHIBITS - MODEL TAX TREATIES 1. OECD Model Tax Convention on Income and on Capital (January 28, 2003) 2. United Nations Model Tax Convention Between Developed and Developing Countries (January 11, 2001) 3. United States Model Income Tax Convention (September 20, 1996)