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Details of International Business Taxation: A Study in the Internationalization of Business Regulation

International Business Taxation: A Study in the Internationalization of Business Regulation
Exact title of book
International Business Taxation: A Study in the Internationalization of Business Regulation
Book author
Sol Picciotto
ISBN
9780899307770
Published
Apr 13, 1992
Language
English
Format
PDF, FB2, EPUB, MOBI
Pages
416
File size (in PDF)
3744 kB

Some brief overview of book

In the twentieth century the application of national taxes to income from international business has created complex yet fascinating issues. The co-ordination of national jurisdiction to tax international income has rested formally on a network of bilateral treaties, but its practical administration has relied on a community of specialists; business advisers on the one hand and national officials on the other. The rapid growth of transnational corporations has put great pressure on the international tax system, especially due to the increasing difficulty of ensuring that the internal transfer prices between related firms in different countries reflect a fair and acceptable allocation of costs and profits.

Furthermore, the widespread use of intermediary companies formed in tax havens has led to complex counter-measures and a constant process of treaty renegotiation and interaction with national law. The increasingly close administrative co-operation of tax authorities has been criticized as secretive and often arbitrary. Yet proposals for a more comprehensive framework and clearer legitimizing principles and procedures have conflicted with both the vested interests of international firms and with sensitivities about national sovereignity.

But major reforms are necessary, even if implemented piecemeal. Using perspectives from law, economics and social science, this book provides a systematic introduction to the major problems of international taxation of business income. In doing so, it retrieves important policy issues that have become buried in technical intricacies of the international taxation system.

About book author

PICCIOTTO specializes in international business regulation and economic law, and in the social theory of law, and is joint Editor of Social and Legal Studies an International Journal. He has taught at the University of Dar es Salaam and the University of Warwick, and is now Professor of Law at the University of Lancaster. ational tax system, especially due to the increasing difficulty of ensuring that the internal transfer prices between related firms in different countries reflect a fair and acceptable allocation of costs and profits. Furthermore, the widespread use of intermediary companies formed in tax havens has led to complex counter-measures and a constant process of treaty renegotiation and interaction with national law.

The increasingly close administrative co-operation of tax authorities has been criticized as secretive and often arbitrary. Yet proposals for a more comprehensive framework and clearer legitimizing principles and procedures have conflicted with both the vested interests of international firms and with sensitivities about national sovereignity. But major reforms are necessary, even if implemented piecemeal.

Using perspectives from law, economics and social science, this book provides a systematic introduction to the major problems of international taxation of business income. In doing so, it retrieves important policy issues that have become buried in technical intricacies of the international taxation system.

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