John Abrahamson - International Taxation of Banking (Series on International Taxation)

International Taxation of Banking

VOLUME 75

Series Editors

Prof. Ruth Mason, University of Virginia School of Law

Prof. Dr Ekkehart Reimer, University of Heidelberg

Prof. Dr Dr h.c. Michael Lang, WU (Vienna University of Economics and Business)

Introduction & Contents

The Series on International Taxation deals with a wide variety of topics in the global tax arena. The authors include many of the field's leading experts as well as talented newcomers. Their expert views and incisive commentary have proven highly useful to practitioners and academics alike.

Objective

The volumes published in this series are aimed at offering high-quality analytical information and practical solutions to international tax practitioners.

Readership

Practitioners, academics and policy makers in international tax law.

Frequency of Publication

2-3 new volumes published each year.

The titles published in this series are listed at the end of this volume.

International Taxation of Banking

John Abrahamson

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ISBN 978-94-035-1094-1

e-Book: ISBN 978-94-035-1095-8
web-PDF: ISBN 978-94-035-1100-9

2020 John Abrahamson

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Preface

This book introduces and analyses the international tax issues which relate to international banking activities extending from taxation in the bank head office country, taxation in countries where branches and subsidiaries are located, and taxation of group service, treasury and intangible property entities. The analysis includes looking at domestic tax laws related to bank company profits, as well as international tax issues related to income and derivative flows and the payment of dividends. The book analyses the OECD Base Erosion and Profits Shifting (BEPS) measures, and how these developments are likely to apply to banking taxation. The book has a broad scope, covering issues such as tax incentives, global trading, group treasury, withholding taxes, shadow banking, green banking, microfinance, bank taxes, FinTech, and transfer pricing.

The book is based on courses on international taxation that I have presented in London, Aberdeen, Durham, Jersey, Paris, Nice, Amsterdam, Rotterdam, Zurich, Lugano, Copenhagen, Warsaw, Limassol, Hong Kong, Singapore, Kuala Lumpur, Seoul, Sydney, Melbourne, Brisbane, Canberra, Perth, Houston, Sao Paulo, Rio de Janeiro, and Mexico City.

I would like to express my thanks to Simon Bellamy and the team at Kluwer Law, who made this book possible. I am deeply indebted to Brian and Valerie Abrahamson, Professor Donald R Rothwell, Professor Harry Reicher, and Professor Malcolm D H Smith for their encouragement and inspiration.

Questions and comments on this publication are very welcome. Contact details: j.abrahamson@sheltonsgroup.com (www.sheltonsgroup.com).

List of Abbreviations