Chapter 1 Introduction to International Taxation
1.1 What is International Taxation?
1.2 Essential Elements of International Taxation
1.3 Tax Principles in an International Environment
1.4 The Role of Supra-national Organizations
1.5 Cross-border Enforcement of Taxes
Reading Material
References
Chapter 2 Tax Jurisdiction
2.1 Tax Jurisdiction of the Concept and Principles to Determine
2.2 Residence Jurisdiction
2.3 Source Jurisdiction
Reading Material
References
Chapter 3 International Double Taxation
3.1 International Double Taxation
3.2 Causes of International Double Taxation
3.3 Needs and Ways for Elimination of Double Taxation
3.4 Double Taxation Avoidance Agreements
Reading Material
References
Chapter 4 Rules to Constrain Tax Jurisdiction
4.1 Rules to Constrain Residence Jurisdiction
4.2 Rules to Constrain Source Jurisdiction
Reading Material
References
Chapter 5 Methods for Elimination of Double Taxation
5.1 Methods in Common Use
5.2 Direct Credit and In Lieu of Credit
5.3 Credit ]imitation
5.4 Indirect Credit Method
5.5 China''s Practice in International Double Taxation Relief
5.6 Tax Sparing Credit
Reading Material
References
Chapter 6 International Tax Avoidance
6.1 International Tax Avoidance and Evasion
6.2 International Tax Avoidance Methods
6.3 Treaty Shopping
6.4 Where Are the Tax Havens?
Reading Material
References
Chapter 7 Transfer Pricing
7.1 Associated Enterprise and Transfer price
7.2 Transfer pricing rules
7.3 Advance Pricing Agreement APA
Reading Material
References
Chapter 8 International Anti-Avoidance Measures
8.1 Introduction
8.2 Anti-avoidance measures
References
Chapter 9 Tax Treaty
9.1 Goal of Tax Treaty
9.2 Origin of Model Convention
9.3 How a Tax Treaty Is Constructed
9.4 Exchange of Information and Mutual Assistance
9.5 When a Treaty Is Applicable?
9.6 How the Treaty Will Terminate?
Reading Material
References
Appendix
1. MODEL CONVENTION WITH RESPECT TO TAXES
ON INCOME AND ON CAPITAL
2. ARTICLES OF THE UNITED NATIONS MODEL
DOUBLE TAXATION CONVENTION BETWEEN
DEVELOPED AND DEVELOPING COUNTRIES
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