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.
General
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