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Vol 23 No 9 Sept/Oct 2018

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International Taxation of Energy Production and Distribution


ISBN13: 9789041191014
Published: May 2018
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £159.00



Low stock.

International Taxation of Energy Production and Distribution introduces and examines significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth approach to policy and practice in the field worldwide, the author focuses on the international tax framework and the tax regimes in leading energy producing and consuming countries.

What’s in this book:

The taxation issues covered include the following:

  • upstream oil and gas and mining taxes;
  • incentives for renewable energy;
  • carbon taxes and emission trading regimes;
  • dividend, interest, and royalty flows;
  • foreign tax credits;
  • permanent establishments;
  • mergers and acquisitions;
  • taxation issues for derivatives and hedging;
  • transfer pricing;
  • regional purchasing, marketing, service, and intangible property structures;
  • free trade agreements and customs unions;
  • dispute resolution; and
  • tax administration and risk management.
Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples and gain practice in identifying and discussing relevant international taxation issues.

How this will help you:

As a practical approach to highlight the relevant issues in international energy taxation, this book serves as a springboard for problem-solving and analysis of the related taxation issues. It is a handbook for corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics to navigate confidently through the maze of the taxation issues in the energy industry.

Subjects:
Taxation, Energy and Natural Resources Law
Contents:
CHAPTER 1
Introduction
CHAPTER 2
Overview of International Taxation and OECD BEPS Measures
CHAPTER 3
Tax Treaty Provisions
CHAPTER 4
Examples of Country Fiscal Systems
CHAPTER 5
Upstream Oil and Gas Taxation: Exploration and Production
CHAPTER 6
Tankers and Bulk Carriers
CHAPTER 7
Pipelines
CHAPTER 8
Downstream Taxation: Refineries and Processing Plants
CHAPTER 9
Coal Exploration and Production
CHAPTER 10
Power Stations and Electricity Networks
CHAPTER 11
Renewable Energy: Supply, Funding, and Taxation Incentives
CHAPTER 12
Carbon Taxes and Emissions Trading Schemes
CHAPTER 13
Contractor Services and Permanent Establishments (PEs)
CHAPTER 14
Value Added Tax
CHAPTER 15
Customs Duties and Tariffs
CHAPTER 16
Holding Companies, Dividends, and Profit Distributions
CHAPTER 17
Interest Deductions in Subsidiaries and Thin Capitalisation
CHAPTER 18
Interest Flows and Hybrid Arrangements
CHAPTER 19
Capital Gains, Group Restructures, and Private Equity
CHAPTER 20
Group Procurement Companies
CHAPTER 21
Group Marketing Companies
CHAPTER 22
Group R&D and Intangible Property Companies
CHAPTER 23
Group Treasury and In-House Banking Companies
CHAPTER 24
Group Service Companies
CHAPTER 25
Group Insurance Companies
CHAPTER 26
Mergers and Acquisitions
CHAPTER 27
Asset Leasing
CHAPTER 28
Tax Havens and Controlled Foreign Corporations Rules
CHAPTER 29
Introduction to Transfer Pricing
CHAPTER 30
Transfer Pricing Issues for Energy Production and Distribution
CHAPTER 31
Intangibles and Transfer Pricing
CHAPTER 32
Intra-group Services, Cost Contribution Arrangements, and Transfer Pricing
CHAPTER 33
Loan Financing, Interest Payments, and Transfer Pricing
CHAPTER 34
OECD BEPS and the Changing Tax Environment
CHAPTER 35
Design of Energy Fiscal Systems
CHAPTER 36
General Conclusions
Case Studies
CASE STUDY 1
Renewable Energy: The Offshore Wind Farm Project, Income Flows, and Permanent Establishments (PE)
CASE STUDY 2
Upstream Oil and Gas: The New Production Sharing Contract (PSC)
CASE STUDY 3
Treasury and Finance: The Group Treasury Centre, Loans, and Derivatives
CASE STUDY 4
Mergers and Acquisition: Private Equity Sale of an Electricity Transmission Network
CASE STUDY 5
Group Research and Development (R&D): Cost Contribution Arrangements (CCA)
CASE STUDY 6
Group Technology: The New Battery Storage System and Tax Treaties
CASE STUDY 7
Group Technology: The Solar Power Station, Transfer Pricing, and Mutual Agreement Procedures (MAP)
CASE STUDY 8
Group Marketing: The Liquefied Natural Gas (LNG) Marketing
Appendices
APPENDIX I
OECD Model Tax Convention 2017: Condensed Version
APPENDIX II
North America Free Trade Agreement (NAFTA): Extracts
APPENDIX III
European Union: Union Customs Code
APPENDIX IV
European Union: Union Customs Code
Table of Cases
Table of Statutes and Directives
Table of Treaties and International Agreements
Index

Series: Series on International Taxation

Taxation, Virtual Currency and Blockchain ISBN 9789403501031
To be published November 2018
Kluwer Law International
£96.00
£111.00
£110.00
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
Published December 2017
Kluwer Law International
£98.00
BRICS and International Tax Law ISBN 9789041194350
Published December 2017
Kluwer Law International
£122.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£123.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£96.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£104.00
Legal Interpretation of Tax Law ISBN 9789041149459
Published September 2014
Kluwer Law International
Out of print
Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave ISBN 9789041128294
Published July 2009
Kluwer Law International
£81.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£110.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£138.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£120.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£116.00
The Improper Use of Tax Treaties ISBN 9789041107374
Published June 1998
Kluwer Law International
£165.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£144.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£181.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£195.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£151.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
£284.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£183.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£177.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£251.00
Towards Corporate Tax Harmonization in the European Community
Adolfo J. Martin JimenezAssociate Professorr of Tax Law, University of Cadiz Law School, Jerez de la Frontera, Spain
ISBN 9789041196903
Published December 0002
Kluwer Law International
£193.00
Tax Treaties and EC Law
ISBN 9789041106803
Published December 0002
Kluwer Law International
£192.00
International Studies in Taxation
ISBN 9789041196927
Published December 0002
Kluwer Law International
£165.00