International Taxation of Banking

Series on International Taxation, Volume Number 75.

About this book:

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.