Bøger af Tom Wesel

This title provides practitioners and students with a concise and clear introduction to international tax law and how it is applied, particularly in relation to the taxation of private investment income. It is a valuable resource for advisers who deal with cross-border tax issues infrequently or are encountering it for the first time. The book covers the background to international tax law and the interaction with national tax law set by individual countries. The amount of cross-border investment by individuals and businesses continues to increase as the world gets smaller. The growth of the digital economy and various world events such as Brexit have increased this trend and as a result tax-payers and their advisers are encountering double taxation issues for the first time. The author examines how the right to tax different types of cross-border flows of income (such as business, property, employment and investment income) and of different types of capital gains is shared between the state where those profits originated (the "source state") and the state where the individual or company receiving them is based (the "residence state"). This is considered both under the OECD Model Treaty that acts as the basis of most double tax treaties and also under EU tax law, which at times overrides and is more favourable to the taxpayer than a double tax treaty. Cross-border inheritance and gift tax treaties are also considered, and how they share out taxing rights between source and residence states. This is followed by an introduction to different kinds of entities used in offshore tax planning, which also describes some of the possibilities of structuring transactions using those entities. It includes warning sections for practitioners to help them avoid getting their fingers burnt: firstly an introduction to anti-avoidance rules under domestic law and tax treaties; secondly a section on international exchange of financial and tax information as well as cooperation on cross-border enforcement of tax debts to warn the reader to assume full transparency of all their transactions for tax purposes rather than rely on the "not found out rule", as was often possible in the past. Finally, in cases where this advice has not been followed, there is a section on regularising under-declared assets. Key areas of commentary including the introductory section, are followed by a short set of revision questions and answers so that readers can self-test whether they have grasped the key points.

This title offers a clear and accessible explanation of the basic principles and many anti-avoidance rules in the UK cross-border taxation of private investments and cross-border trading. It is structured into four sections: General Principles - an introductory section for those who have limited knowledge in these areas. Inbound to the UK - providing an overview of the advantages and pitfalls of the UK tax system for foreign individuals and entities, this section deals with the principal taxes affecting non-resident individuals, companies and other entities establishing a UK presence or undertaking transactions with the UK from abroad. Outbound from the UK- considers the practical considerations relating to investments or trading operations abroad, dealing with the taxation of UK resident individuals, companies and other entities with foreign interests - both the extensive anti-avoidance rules in relation to foreign investments and trading operations as well as the available tax breaks; reviews the operation of double tax treaties, the taxation of interests in offshore trusts and of the anti-avoidance rules for SMEs and larger companies; and outlines the taxation of employees going to work abroad. Tax Planning - deals with a variety of tax break opportunities for direct investments in the UK as well as offshore planning opportunities for individuals (using trusts, other estate planning vehicles and insurance products), and for companies - in particular for SMEs; highlights potential tax pitfalls for those moving to or from the UK, in particular returning residents; and features numerous practical examples of key principles alongside matters such as the General Anti-abuse Rule and the disclosure requirements for DOTAS, DAC6 and certain tax avoidance schemes. The result is a readable and practical overview of the UK's offshore tax rules; one which is valuable both to newcomers to UK cross-border taxation, as well as to the experienced practitioner who needs to refresh their knowledge of the relevant rules, and wants an up-to-date and reliable source to refer to.