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Taxation of Trusts, Foundations and Similar Arrangements in a Global Setting

Edited by: Andrés Báez Moreno, Mario Tenore, Vikram Chand, Svetislav V. Kostić

ISBN13: 9789403523194
To be Published: October 2025
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: Hardback
Price: £169.00





Taxation of Trusts, Foundations and Similar Arrangements in a Global Setting is an exceptional book that offers practitioners extensive global coverage of direct taxation of trusts and foundations, wealth taxes, procedural matters, philanthropy, and international tax planning. One of the most complex areas of tax practice concerns the interwoven area of trusts, foundations and similar arrangements, particularly when an international element is involved.

>p> Eminent authors and practitioners have contributed to this compendium offering both theoretical and practical perspectives. This edited volume provides clear and accessible guidance on the following taxation issues and topics:
  • trusts and private international law;
  • trends in domestic taxation of trust and foundations worldwide;
  • trusts and abuse in a domestic law context;
  • tax treaty interpretation issues;
  • special tax cooperation agreements;
  • trusts and value-added tax;
  • effect of the proposed Business in Europe Framework for Income Taxation (BEFIT) Directive;
  • flow-through entities and the OECD Pillar Two;
  • transfer pricing issues;
  • philanthropic holding foundations; and
  • special focus on jurisdictions unfamiliar with trusts and foundations.

Tax lawyers and other tax professionals will gain a comprehensive understanding of how trusts and foundations are taxed across different jurisdictions and confidently navigate complex taxation issues, including often-overlooked and cross-border aspects. The essential insights of this book will also prove invaluable to academic research, policy development, and practical tax decision-making in a globalized environment.

Subjects:
Taxation
Contents:
PART I: Non-tax Approach to Trusts and Similar Arrangements
1. Trust and Private International Law: Critical Analysis, Javier Carrascosa González
2. Is Private Law Crucial When Dealing with the Taxation of Trusts? The Law of Trusts for Civilian (Tax) Lawyers, Andrés Báez Moreno & Svetislav V. Kostic

PART II: Tax Treatment of Trusts and Foundations under Domestic Law
3. Trends in Common Law Countries in the Tax Treatment of Trusts, Mark Brabazon
4. Trends in Taxation of Foundations, Marcel R. Jung
5. Trusts and Abuses in the Context of Domestic Law, Álvaro de la Cueva & Carmen Carmona

PART III: Tax Treaty Issues with Trusts, Foundations and Similar Arrangements
6. Tax Treaty Interpretation Issues Relating to Trusts, Foundations, Similar Arrangements, Mario Tenore
7. Tax Treaty Conflicts in Relation to Attributing Trust Income and the Vexed Issue of Beneficial Ownership as It Relates to Trusts, Michael McGowan
8. Trust and Tax Treaty Abuse, Stefano Loconte
9. International Taxation of Foundations and Trusts According to Special Tax Cooperation Agreements, Martin Wenz, Niklas Kaiser & Ramona Lässer

PART IV: Specific Challenges of Trusts and Similar Arrangements for Transaction and Wealth Tax Purposes
10. Trusts and Taxes on Wealth, Violeta Ruiz Almendral
11. Wealth Taxes and Wealth Planning: The Role of Foundations, Peter Hongler & Subiksha Thirumamany
12. Trusts and Value Added Tax, Karoline Spies & Dominic Krenn

PART V: Trusts and Foundations: EU Tax Law Implications
13. Trusts, Foundations and Similar Arrangements and the EU Fundamental Freedoms, Moritz Scherleitner & Rita Szudoczky
14. The Impact of the EU Public CbCR Directive and the Proposed BEFIT Directive on Trusts, Foundations and Similar Arrangements, Jean-Philippe Van West

PART VI: Impact of Pillar Two and Recent EU Corporate Tax Initiatives on Trusts, Foundations and Similar Arrangements
15. Impact of Pillar Two Scoping Rules on Trusts, Foundations and Similar Arrangements, Kinga Romanovska
16. Flow-Through Entities and the OECD Pillar Two, Leopoldo Parada
17. Transfer Pricing Issues When Dealing with Trusts, Foundations, and Similar Arrangements, Amanda Pletz & Ayushi Rungta

PART VII: Trusts, Foundations and Other Similar Arrangements for Philanthropic Purposes
18. Philanthropic Holding Foundations: Reassessing a Tax Definition of Philanthropy, Giedre Lideikyte Huber
19. Under What Circumstances Can Stewardship Foundation Structuring Be a Solution to Families, Enterprises and Society at Large? , Ineke A. Koele
20. Enterprise Foundations: Choosing the Right Purpose, Mark Ørberg & Søren Friis Hansen