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Vol 23 No 5 May/June 2018

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International Taxation of Manufacturing and Distribution

ISBN13: 9789041166647
Published: March 2016
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £149.00

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International Taxation of Manufacturing and Distribution introduces and analyses the international tax issues which relate to international manufacturing and distribution activities - extending from the tax regime in the country where the manufacturing activities are located, through regional purchase and sales companies - to the taxation of local country sales companies.

The analysis includes looking at domestic tax laws related to manufacturing and distribution company profits, as well as international tax issues related to income flows and payment of dividends. The book has a broad scope, covering similar issues such as customs tariffs, VAT, contract manufacturing and tolling, group treasury, withholding taxes, mergers and acquisitions, asset finance and leasing, derivatives, and related transfer pricing issues.

Among the topics and issues analysed are the following:-

  • foreign tax credits;
  • taxation in the digital economy;
  • tax incentives for export and investment;
  • intellectual property;
  • group treasury companies;
  • controlled foreign corporation provisions;
  • free trade agreements and customs unions;
  • transfer pricing;
  • role of tax treaties;
  • hedging;
  • related accounting issues;
  • deferred tax assets and liabilities;
  • tax risk management;
  • supply chain management;
  • depreciation allowances; and
  • carry-forward tax losses.
The book includes descriptions of twenty-one country tax systems and ten detailed case studies as specific examples for the analysis. Up-to-date and detailed attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance.

The most important portions of the OECD Model Tax Convention, the United Nations Model Tax Convention, the North American Free Trade Agreement, and the EU Union Customs Code are presented in appendices. The content of this book clearly identifies and explains the management of research and development and intellectual property used in manufacturing as well as the structures used in mergers and acquisitions, group treasury operations, and transfer pricing issues for manufacturing groups.

International Taxation of Manufacturing and Distribution provides the most thorough treatment of its subject available. As a full-scale commentary and analysis of international taxation issues relating to multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer.

It serves as a springboard for problem solving by providing case studies (including answers) and acts as an aid to practitioners in mastering international taxation issues concerning global manufacturing and distribution. It is, therefore, of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.


  • Introduces and analyses international tax issues for manufacturing and distribution.
  • Includes examples of country tax regimes.
  • Analyses manufacturing tax issues including tax incentives for export and investment.
  • Analyses permanent establishment issues relating to contract manufacturing and tolling structures, VAT and customs duties.
  • Explains international tax issues relating to interest and dividend flows, capital gains, and foreign tax credits and the related tax treaty issues.
  • Explains the management of research and development and intellectual property used in manufacturing.
  • Identifies and explains the structures used in mergers and acquisitions, group treasury operations, and transfer pricing issues for manufacturing groups.

  • An essential guide for tax accountants, lawyers, economists, financial managers and government officials.
  • Understand the structures used by multinational manufacturing groups.
  • Practice problem solving with case studies and included answers.
  • Master the international taxation issues of global manufacturing and distribution.

CHAPTER 1 Introduction.
CHAPTER 2 Overview of International Taxation.
CHAPTER 3 Examples of Country Tax Systems.
CHAPTER 4 Manufacturing.
CHAPTER 5 Procurement Companies.
CHAPTER 6 Distribution and Regional Sales Companies.
CHAPTER 7 Shipping and Air Transport.
CHAPTER 8 Value Added Tax.
CHAPTER 9 Customs Duties and Tariffs.
CHAPTER 10 The Digital Economy.
CHAPTER 11 Social Security Taxes.
CHAPTER 12 Tax Incentives.
CHAPTER 13 Taxation Issues for Dividends and Profit Distributions.
CHAPTER 14 Taxation Issues for Funding and Interest Flows.
CHAPTER 15 Group Restructures and Taxation Issues for Capital Gains.
CHAPTER 16 R&D and Intellectual Property.
CHAPTER 17 Treasury and In-House Banking Companies.
CHAPTER 18 Group Insurance Companies: Captive Insurance.;
CHAPTER 19 Taxation Issues for Mergers and Acquisitions.
CHAPTER 20 Acquisitions and Sale and Purchase Agreements.
CHAPTER 21 Tax Due Diligence for Mergers and Acquisitions.
CHAPTER 22 Asset Leasing.
CHAPTER 23 Derivatives: Options, Forwards and Swaps.
CHAPTER 24 Interest Deductions in Subsidiaries and Thin Capitalisation.
CHAPTER 25 Tax Havens and Controlled Foreign Corporations Rules.
CHAPTER 26 Introduction to Transfer Pricing.
CHAPTER 27 Transfer Pricing Issues for Manufacturing and Distribution.
CHAPTER 28 Intangibles and Transfer Pricing.
CHAPTER 29 Intra-group Services and Transfer Pricing.
CHAPTER 30 Loan Financing, Interest Payments and Transfer Pricing.
CHAPTER 31 General Conclusions.

CASE STUDY 1 International Tax Issues: Investing into Malaysia.
CASE STUDY 2 Permanent Establishments and Sales Activities.
CASE STUDY 3 Tax Residence and Domestic Tax Laws.
CASE STUDY 4 Permanent Establishments and Manufacturing.
CASE STUDY 5 Repatriating Profits: Tax Treaties and Domestic Tax Laws.
CASE STUDY 6 Asset Acquisitions and Mergers and Acquisitions Planning.
CASE STUDY 7 Analysis of Due Diligence Reports for Mergers and Acquisitions.
CASE STUDY 8 Group Funding and Treasury Structures.
CASE STUDY 9 Manufacturing, Distribution and Group Transfer Pricing.
CASE STUDY 10 Group Intellectual Property and Transfer Pricing .

APPENDIX I OECD Model Tax Convention 2014 – Condensed Version.
APPENDIX II North American Free Trade Agreement (NAFTA) – Summary.
APPENDIX III North American Free Trade Agreement (NAFTA) – Summary of Terms.
APPENDIX IV North America Free Trade Agreement (NAFTA) – Extracts.
APPENDIX V European Union – Union Customs Code.
APPENDIX VI European Union – Union Customs Code.

Table of Cases.
Table of Statutes and Directives.
Table of Treaties and International Agreements.