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International Business Taxation
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The taxation of international business is a vital political and social issue, as well as raising
many fascinating legal, political and economic questions. Taxation is the point of most direct
interaction between government and citizens, the state and the economy. Yet the technical
complexities of taxation often make informed debate difficult. This book aims to provide a
survey of the development and operation of international business taxation which is
sufficiently detailed to provide an adequate understanding of its complexities, yet analytical
enough to bring out the important policy issues.
The international interaction of tax systems has been recognized since at least the First
World War as an important element in international finance and investment. With the growth
of state taxation of income, including business income or profits, each state had to adapt its
tax measures to its international payments and investment flows. Conflicts and differential
treatment between states led to pressures from business for the elimination of international
double taxation. Although early hopes of a comprehensive multilateral agreement allocating
jurisdiction to tax were soon dashed, a loose system for the co-ordination of tax jurisdiction
was laboriously constructed.
This was composed of three related elements. First, national tax systems accepted, to a
greater or lesser extent, some limitations on their scope of application. Second, a process of
co-ordination by international agreement emerged, in the form of a network of bilateral tax
treaties, based on model conventions, adapted to suit the political and economic circumstances
of each pair of parties. The third element was the growth of a community of international
fiscal specialists, composed of government officials, academic experts and business advisors
or representatives. It was they who devised the model conventions, through lengthy
discussion and analysis and countless meetings. They also negotiated the actual bilateral
treaties based on the models, the experience of which in turn contributed to subsequent
revisions of the models. Finally, the allocation to national tax jurisdictions of income derived
from international business activities has depended, to a great extent, on bargaining processes
also carried out by such specialists, on behalf of the state and of business.
SOL PICCIOTTO - Personal Name
2nd Edition
0 297 82106 7
NONE
International Business Taxation
Management
English
2013
1-400
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