There has recently been much discussion of the possible use of internationally coordinated indirect taxes, or equivalent charges, on international aviation, whether as a source of finance for development or as part of a response to heightened concerns with climate change. This paper considers the strengths and weaknesses of the leading candidate instruments of this kind. It argues that, on both policy and administration grounds, the case for increasing indirect taxes on international aviation is strong: the indirect tax burden on international aviation is very low, yet aviation contributes significantly to border-crossing environmental damage, is just as proper an object of taxation as any other commodity, and incipient tax competition is likely to result in these taxes being set at inefficiently low levels. But the form(s) in which such taxes are levied matters: a tax on aviation fuel would address the key border-crossing externalities most directly; a tax on final ticket values would have greater revenue potential, and perhaps some distributional advantage; departure/arrival taxes face the least legal obstacles, but are much blunter instruments. Optimal policy, it is shown, typically requires deploying both a fuel tax and a ticket tax, and the paper explores, both in principle and by simulation, the key considerations and trade-offs involved in designing a suitable indirect tax regime for international aviation.
Air law has recently grown in significance. Drawing on international and national instruments and a wealth of case law from many jurisdictions, including the International Court of Justice, this book covers the role of international law in such matters as legal consequences arising from the use of automation in civil aviation, the carriage of the elderly and disabled by air, unlawful interference with civil aviation, protection of the environment, and the legal management of aviation security. Published under the Transnational Publishers imprint.
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.
The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.
The United Nations in Global Tax Coordination fills the decade-long knowledge gap in international tax history concerning the UN Fiscal Commission, which functioned as the overarching fiscal authority during the early post-World War II economic order. With insights from political economy and international relations scholarship, this critical archival examination chronicles the tenacious activism by post-colonial developing countries to preserve source taxation rights, and by the UN Secretariat in championing the development of equitable tax rules. Such activism would ultimately lead developed countries to oust the UN as a forum for international tax norm setting. The book includes a revealing prehistory of the wartime work of the League of Nations that questions the legitimacy of the Mexico Model, the first model tax convention between developed and developing countries. This expertly researched work is essential reading for understanding the roles of politics, states, secretariats and private actors in directing global tax coordination.
Many of the problems and opportunities facing society today are determined by issues of mobility. Access to people, products, information and resources has emerged as a priority in the foreign policies of most states. Inevitably, considerations of national interest have played a central role in the structure and operations of the international aviation system. Meanwhile, air transport has been a catalyst for the phenomenon of globalization. This first in-depth exploration of the vital relationship between aviation policy and national interest in todays global economy focuses on those areas of concern where the international community has common ground or where conflicts of interest are most likely to arise. Revealing deeply informed perspectives gained from decades of distinguished public service in many areas of aviation policy, Erwin von den Steinen reviews the rules that govern the conduct of commercial air services between nations and considers the prospects of aviation in the 21st Century. He explains how timely understanding of national interest can provide a context for global and local policy to connect, and why the international aviation system is vital for the peaceful and sustainable development of modern states and societies. With such insights and powerful, practical recommendations, von den Steinens analysis will be of enormous value to those concerned with air transport, from technical research and design to the highest levels of government, as well as to lawyers and academics in international law and relations. anda tour of the major issues in international aviation law and policy under the guidance of an authentic homme engageand Ultimately, this book is the work of someone who deeply appreciates the aviation industry both at its technical level, that of its often-frustrating machinations of law and policy, and also at the emotional level of a special business that exemplifies freedom and imagination like few others do.and Brian F. Havel andThe Introduction has one of the best free flowing leads to a book detailing the politics of aviation and diplomacy I have come acrossand . I commend this book to lawyers, diplomats and students of aero-politics and lawand . I would prescribe this book to my graduate students as compulsory reading for their course in Aero-political and legal Environment.and Dr Ruwantissa Abeyratne
'Taxation affects all of us, directly or indirectly, on a daily basis in numerous ways. For those involved in studying and researching taxation, matters of definition and understanding of taxation terms frequently arise. Simon James' 1998 first edition has been where I first turn to as a reference source to provide insightful, concise and readily understandable explanations. Specifically A Dictionary of Taxation is an essential source whether the occasion is teaching, responding to student queries, or supporting one's own research. I congratulate Simon in preparing this second edition and would encourage a future edition to emerge significantly sooner than the gap between the first two editions. Every researcher and teacher of taxation should have a copy of this second edition on their desk.' Adrian Sawyer, University of Canterbury, New Zealand 'A Dictionary of Taxation, Second Edition is comprehensive and more substantive than a simple listing of definitions and will prove to be an enormously valuable reference. Professor James provides just the right amount of detail and insight for each entry, frequently commenting on the historical evolution of a term, and for many entries, providing a list of the original sources upon which the entry is based. I highly recommend this directory to academic researchers, makers of public policy, and private sector professionals.' Carl P. Kaiser, Washington and Lee University, US 'Simon James' second edition of A Dictionary of Taxation has arrived at last! Tax is one of those things that is universal and unavoidable, and at the same time, dynamic and intriguing. James does a sterling job at capturing so many terms herein, not just technical explanations, but also their history and significance. There are also helpful suggestions for further reading. Both experts and novices alike will find this an interesting and very useful text to have close at hand.' Margaret McKerchar, Australian School of Taxation and Business Law (Atax) 'I have known Simon for many years, through working in our respective roles as committee members for the Chartered Institute of Taxation. Simon has an extremely wide knowledge of taxation matters, which is ably demonstrated in this dictionary of tax terms and phrases. It is an essential guide in unraveling the mysteries of professional "tax talk" for the non practitioner. For those interested in obtaining further information or guidance there are many useful references to other works.' Dale Simpson, Chairman, South West England Region of the Chartered Institute of Taxation and Partner, Thomas Westcott, UK This second edition of the Dictionary of Taxation contains over 200 new or substantially revised entries to enhance the existing wide range of accessible definitions and terms used to describe various aspects of tax and tax systems around the world. The entries relate to the analysis of taxation, key concepts, major developments and controversies in taxation. The Dictionary draws on economic, accounting and legal aspects of taxation as well as the contributions of other social sciences to the understanding of taxation and its effects. Sorted alphabetically, with cross referencing, each entry presents the essential points of a particular law, accountancy practice or economic concept. Additionally this revised and updated Dictionary offers a guide to readers of other literature on certain concepts or practices. Written in an accessible style, it will be indispensable to all those who need to know more about the concepts of taxation including practitioners, academics and students.