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International Taxation of Banking


ISBN13: 9789403510941
Published: February 2020
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £168.00



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International Taxation of Banking introduces and analyses the international tax issues which relate to international banking activities. Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups.

What’s in this book:

The content of this book clearly identifies and explains the management of research and development and intangible property used in the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book examines such issues as the following:

  • taxation of dividends and branch profits derived from other countries;
  • transfer pricing and branch profit attribution;
  • taxation of global trading activities;
  • tax risk management;
  • provision of services and intangible property within multinational groups;
  • taxation treatment of research and development expenses;
  • availability of tax incentives such as patent box tax regimes;
  • swaps and other derivatives;
  • loan provisions and debt restructuring;
  • financial technology (FinTech);
  • group treasury, interest flows, and thin capitalisation;
  • tax havens and controlled foreign companies; and
  • taxation policy developments and trends.
Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail.

How this will help you:

The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will serve as an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Subjects:
Banking and Finance
Contents:
Preface
List of Abbreviations
CHAPTER 1. Introduction
CHAPTER 2. The Banking Regulatory Framework
CHAPTER 3. Retail and Commercial Banking
CHAPTER 4. Investment Banking
CHAPTER 5. Introduction to International Tax
CHAPTER 6. Tax Treaties
CHAPTER 7. OECD BEPS Developments
CHAPTER 8. Bank Parent Companies
CHAPTER 9. Bank Branches
CHAPTER 10. Other Bank Permanent Establishments
CHAPTER 11. Representative Offices
CHAPTER 12. Derivatives
CHAPTER 13. Loan Provisions and Debt Restructuring
CHAPTER 14. Value Added Tax: VAT
CHAPTER 15. Bank Taxes: Financial Transaction Taxes and Bank Levies
CHAPTER 16. Dividends and Profit Distributions
CHAPTER 17. Group Treasury, Interest Flows and Thin Capitalisation
CHAPTER 18. Intangible Property: IP
CHAPTER 19. Tax Havens and Controlled Foreign Companies: CFCs
CHAPTER 20. Introduction to Transfer Pricing
CHAPTER 21. Transfer Pricing and Bank Branch Attribution
CHAPTER 22. Transfer Pricing and Global Trading
CHAPTER 23. Transfer Pricing and Loans
CHAPTER 24. Transfer Pricing and Intangibles
CHAPTER 25. Transfer Pricing and Services
CHAPTER 26. Islamic Banking
CHAPTER 27. Green Banking
CHAPTER 28. Microfinance Banking
CHAPTER 29. Financial Technology: Fintech
CHAPTER 30. Shadow Banking
CHAPTER 31. Automatic Exchange of Information: CRS and FATCA
CHAPTER 32. Taxation Policy Developments
CHAPTER 33. General Conclusions
Case Studies
Case Study 1. The Malaysia Branch: Permanent Establishments and Treaties
Case Study 2. The Korean Bank Acquisition: Group Interest Deductions
Case Study 3. Group Technology: Global Risk Management Cloud Software and Tax Treaties
Case Study 4. The Italian Branch: Branch Attribution
Case Study 5. Branch Profit Attribution: Corporate Loans and Global Trading
Case Study 6. The Group Advertising Centre: Transfer Pricing Dispute
Appendix.
OECD Model Tax Convention 2017
Table of Cases
Table of Statutes and Directives
Table of Treaties and International Agreements
Index

Series: Series on International Taxation

The Resolution of International Tax Disputes ISBN 9789403520889
To be published May 2024
Kluwer Law International
£75.00
The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model ISBN 9789403542973
To be published May 2024
Kluwer Law International
£92.00
Taxation of Derivatives and Cryptoassets 2nd ed ISBN 9789403523835
To be published April 2024
Kluwer Law International
£143.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed (eBook) ISBN 9789403546766
Published December 2023
Kluwer Law International
£144.00
(ePub)
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Double Non-taxation and the Use of Hybrid Entities 2nd ed ISBN 9789403546667
Published December 2023
Kluwer Law International
£144.00
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea ISBN 9789403534077
Published November 2023
Kluwer Law International
£81.00
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea (eBook) ISBN 9789403534176
Published November 2023
Kluwer Law International
£81.00
(ePub)
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The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective (eBook) ISBN 9789403537627
Published August 2022
Kluwer Law International
£96.00
(ePub)
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The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective ISBN 9789403537412
Published August 2022
Kluwer Law International
£96.00
£139.00
£139.00
(ePub)
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Coordination and Cooperation: Tax Policy in the 21st Century ISBN 9789403537405
Published December 2021
Kluwer Law International
£128.00
Coordination and Cooperation: Tax Policy in the 21st Century (eBook) ISBN 9789403537603
Published December 2021
Kluwer Law International
£128.00
(ePub)
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Regulation and Tax in Space (eBook) ISBN 9789403533940
Published May 2021
Kluwer Law International
£79.00
(ePub)
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Exploring the Nexus Doctrine In International Tax Law (eBook) ISBN 9789403533643
Published May 2021
Kluwer Law International
£75.00
(ePub)
Buy
Regulation and Tax in Space ISBN 9789403533933
Published May 2021
Kluwer Law International
£79.00
Exploring the Nexus Doctrine In International Tax Law ISBN 9789403533636
Published May 2021
Kluwer Law International
£75.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed (eBook) ISBN 9789403520643
Published July 2020
Kluwer Law International
£375.00
(ePub)
Buy
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed ISBN 9789403520612
Published July 2020
Kluwer Law International
£375.00
International Taxation of Banking (eBook) ISBN 9789403510958
Published February 2020
Kluwer Law International
£168.00
(ePub)
Buy
Tax Treaty Residence of Entities ISBN 9789403513010
Published November 2019
Kluwer Law International
£108.00
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules ISBN 9789403510743
Published August 2019
Kluwer Law International
£130.00
Tax and the Digital Economy: Challenges and Proposals for Reform ISBN 9789403503615
Published May 2019
Kluwer Law International
£111.00
Taxation, Virtual Currency and Blockchain ISBN 9789403501031
Published December 2018
Kluwer Law International
£96.00
International Taxation of Energy Production and Distribution ISBN 9789041191014
Published May 2018
Kluwer Law International
£159.00
Out of print
£110.00
£110.00
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
Published December 2017
Kluwer Law International
£119.00
BRICS and International Tax Law ISBN 9789041194350
Published December 2017
Kluwer Law International
£149.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£149.00
Other Income under Tax Treaties ISBN 9789041166104
Published September 2015
Kluwer Law International
£241.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£154.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£167.00
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
£125.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£173.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£212.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£183.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£177.00
The Improper Use of Tax Treaties ISBN 9789041107374
Published June 1998
Kluwer Law International
£253.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£220.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£279.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£300.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£233.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
Out of print
Tax Treaties and EC Law
ISBN 9789041106803
Published November 1990
Kluwer Law International
£295.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£281.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£273.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£388.00
International Studies in Taxation
ISBN 9789041196927
Published December 1968
Kluwer Law International
£253.00
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 1968
Kluwer Law International
£296.00