International Commercial Tax

International Commercial Tax

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Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.If that view is right, then in my judgment the only possible conclusion... is that L.P. were neither brokers nor general ... L.P. was little more than the English end of Kaiapoia#39;s business, doing all that had to be done for them, and far more than is truly brokerlike. ... A classic example of the type of agent falling within Article 5(6) is an insurance broker that sells insurance for a ... Services PE The above discussion has identified a number of sensitive areas where tax planning may ensure thatanbsp;...

Title:International Commercial Tax
Author: Peter Harris, David Oliver
Publisher:Cambridge University Press - 2010-07-22

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